transfer pricing

Transfer pricing refers to the pricing of transactions - goods, services, intangible assets or financing - between related or connected entities within the same corporate group (parent company, subsidiaries, affiliates, free-zone entities, etc.).

With the introduction of corporate tax and TP regulations in the UAE (effective since 2023), adherence to TP rules has become critical for companies operating in Dubai and across the UAE.

Under these rules, all inter-company or intra-group transactions must follow the “arm’s length principle” - i.e. the terms must be comparable to those that independent, unrelated parties would agree under similar circumstances.

Non-compliance or lack of proper documentation may lead to adjustments by tax authorities, penalties, or double taxation - especially for cross-border groups.

Therefore, robust transfer pricing compliance, documentation, and expert advisory are essential for MNEs, holding groups, and any business with related-party transactions in UAE.

Our Transfer Pricing Services - What We Provide

We offer comprehensive and tailored transfer pricing services in Dubai / UAE, matching international best practices (OECD guidelines) and local regulatory requirements. Our offerings include:

1. Transfer Pricing Advisory & Policy Development

• Drafting and reviewing your transfer pricing policy for inter-company transactions (goods, services, intangibles, financing), aligned with UAE regulations and international standards.

• Functional analysis (Functions-Assets-Risks, FAR), economic analysis, value chain / supply chain reviews, and identification of intercompany transactions subject to TP rules.

• Helping you choose the most appropriate TP method (Comparable Uncontrolled Price (CUP), Resale Price, Cost-Plus, Transactional Net Margin Method (TNMM), Profit Split, or other methods), depending on the nature of transactions and availability of comparable data.

2. Transfer Pricing Documentation (Master File, Local File, CbCR / Disclosure)

• Preparation of all required documentation: local file, master file, country-by-country reports (CbCR), TP disclosure forms - as required under UAE Corporate Tax regulations.

• Benchmarking studies and economic analyses to substantiate that inter-company prices comply with arm’s length principle - including industry and regional comparables.

• Maintenance and updating of documentation, functional analyses, transactional data, to ensure ongoing compliance through audit cycles.

3. Transfer Pricing Compliance, Tax Returns & Reporting Support

• Assistance with filing TP disclosures, reporting intercompany transactions, and meeting compliance obligations under UAE Corporate Tax law.

• Support in preparation for audits or tax authority review: documentation readiness, defense of your TP policy, transaction justification, risk mitigation.

4. Strategic TP Planning & Supply-Chain / Value-Chain Advisory

• Advisory on restructuring supply chains or business operations to optimise transfer pricing models, align pricing with value creation, and reduce tax risk while staying compliant.

• Customised analyses for inter-company financing, licensing of intangibles, intra-group services, royalties, cost-sharing arrangements - setting defensible prices, aligned with commercial reality and regulations.

5. Ongoing Advisory, Risk Management & Audit Defense

• Periodic review of TP policies and inter-company arrangements to adapt to business changes, regulatory updates, and evolving OECD / UAE tax rules.

• Support in case of tax authority inquiries, adjustments, or disputes - preparing documentation, comparability analyses, transfer-pricing defense, and negotiation strategies.

Key Benefits for Your Business

By engaging professional transfer pricing services, you gain:

• Regulatory compliance - alignment with UAE Corporate Tax and Transfer Pricing regulations, avoiding penalties, double taxation risks, audit adjustments.

• Reduced tax risk & audit exposure - robust documentation, proper methods, defensible inter-company pricing, minimizing chances of adjustments or disputes.

• Financial transparency & defensibility - inter-company transactions priced at arm’s length, backed by economic analysis and benchmarking, acceptable for auditors, regulators, investors.

• Flexibility and strategic advantage - ability to manage group structure, cross-border operations, supply-chain changes, and value-chain allocation while staying compliant.

• Scalability for growing businesses - suitable both for SMEs and large multinational groups with complex structures, multiple subsidiaries, free-zone entities, cross-jurisdiction operations.

• Peace of mind and professional support - ongoing advisory, documentation maintenance, audit-ready records, expert defence if needed.

Who Should Use our Transfer Pricing Services

Our services are ideal for:

• Multinational enterprises (MNEs) with related-party transactions (goods, services, financing, IP) involving UAE entities or cross-border affiliates.

• Holding companies, corporate groups or businesses with subsidiaries, free-zone entities or complex group structures operating in UAE.

• Companies experiencing supply-chain changes, inter-company restructuring, or cross-border operations requiring defensible pricing and documentation.

• Businesses preparing for audits, FTA “transfer pricing scrutiny”, or planning to expand operations, relocate subsidiaries, or introduce new inter-company services / financing.

• Entities requiring compliance with international tax standards (OECD guidelines) as well as UAE local tax law, ensuring long-term stability and defensibility.

Our Approach: How We Work with Clients

1. Initial diagnostic & transactional review - assess group structure, inter-company transactions, existing pricing, contractual arrangements, supply/value chains.

2. Functional and economic analysis (FAR + benchmarking) - identify transactions, risks, functions and assets; select appropriate TP method based on business model and comparability data.

3. Policy drafting and documentation preparation - develop robust TP policy, Local / Master / CbCR files, report templates, disclosure forms as per UAE requirements.

4. Implementation & compliance integration - embed TP policy into accounting, invoicing, intercompany contracts, finance and audit controls; ensure that all related-party transactions follow arm’s length pricing.

5. Ongoing monitoring, support & updates - periodic reviews, update documentation, adapt TP policy when business changes, support audits, respond to FTA / tax-authority inquiries.

6. Audit defense & advisory services - prepare defensible documentation and analyses, assist in negotiations, represent interests, and mitigate transfer pricing risk.

Why Choose Us for Transfer Pricing Services in Dubai / UAE

• Deep expertise in international TP rules and UAE local regulations: we merge global best practices (OECD-based standards) with comprehensive understanding of UAE Corporate Tax law and local compliance requirements.

• Tailored solutions for your business model: we don’t use “one-size-fits-all” - our TP strategies reflect your business structure, inter-company flows, industry specifics, supply chain, and commercial logic.

• Audit-ready documentation and defence capability: we prepare complete, defensible documentation (master file, local file, benchmarking, reporting) - minimizing risk in case of audits or cross-jurisdictional scrutiny.

• Strategic advisory beyond compliance: we help optimise your inter-company transactions, restructure value chains, align tax efficiencies with business goals - not just follow rules.

• Scalability and ongoing support: from SMEs to large MNEs - we adapt to your size and evolving needs; we support you through growth, restructurings, regulatory changes, audits and beyond.