Transfer pricing
that holds up.

UAE transfer pricing landscape

Transfer pricing in the UAE has moved from being a soft consideration to a hard compliance requirement. With UAE Corporate Tax now in effect, the FTA expects taxpayers to demonstrate that related-party transactions are priced on an arm's length basis — supported by formal documentation.

The UAE rules align with OECD principles, with specific local nuances. Master file, local file and CbCR requirements apply to qualifying groups.

What we deliver

• Master file — group-level documentation describing the multinational group's business and TP policies
• Local file — entity-level documentation of related-party transactions with benchmarking analyses
• CbCR — Country-by-Country Reporting for qualifying groups
• Benchmarking studies — comparable searches and arm's length range analysis
• Intercompany agreements — drafting and reviewing the contracts that govern related-party transactions
• TP policy design — for groups establishing or restructuring their TP framework
• FTA audit defence — TP-specific defence in CT audits

Who needs UAE TP documentation

Generally, UAE entities that are part of multinational groups with revenue exceeding the UAE TP thresholds, and any entities with material related-party transactions. We help businesses determine their specific obligations and prepare appropriate documentation.