UAE Transfer Pricing Advisory, Benchmarking Study, Local File & Master File Support
Transfer Pricing has become one of the most significant areas of UAE Corporate Tax compliance following the introduction of Federal Decree Law No. 47 of 2022 on the Taxation of Corporations and Businesses. Businesses operating in the UAE that engage in transactions with Related Parties or Connected Persons are now required to ensure that such transactions comply with the Arm’s Length Principle. The UAE Transfer Pricing framework broadly aligns with internationally accepted OECD-aligned transfer pricing principles and applies to various controlled transactions including management fees, intercompany services, financing arrangements, royalty payments, procurement structures, cost sharing arrangements, imports, exports, and other related party dealings.
Federal Tax Authority (FTA)
The FTA has issued detailed Corporate Tax guidance relating to:
- Related Parties,
- Connected Persons,
- Arm’s Length Principle,
- Transfer Pricing methods,
- benchmarking analysis,
- Local File and Master File requirements,
- and transfer pricing disclosure obligations.
The UAE Corporate Tax framework requires businesses to maintain supporting documentation and demonstrate that related party transactions are priced consistently with market conditions that independent parties would agree under comparable circumstances.
Businesses operating in the UAE may be required to assess:
- related party relationships,
- ownership structures,
- family business arrangements,
- and connected person transactions
under UAE Corporate Tax rules. The UAE regime includes specific provisions relating to:
- 50% ownership thresholds,
- voting rights,
- profit entitlement,
- significant influence,
- and connected person payments involving owners, directors, partners, and related individuals. The FTA also expects businesses to maintain sufficient documentation supporting the commercial rationale and arm’s length nature of transactions involving related parties and connected persons.
Depending on applicability thresholds and business structure, UAE businesses may need to maintain:
Transfer Pricing Documentation
including:
- Transfer Pricing Disclosure Forms,
- Local File,
- Master File,
- Benchmarking Studies,
- FAR (Functions, Assets & Risks) Analysis,
- and intercompany agreements.
The FTA may request transfer pricing documentation and supporting economic analysis during reviews, audits, or assessments. Businesses lacking robust documentation may face:
- transfer pricing adjustments,
- penalties,
- audit scrutiny,
- and increased compliance risk.
The UAE Transfer Pricing framework also includes simplified treatment for qualifying low value-adding intra-group services under certain conditions. In specific cases, qualifying routine support services may apply a simplified:
5% mark-up on relevant costs
subject to prescribed conditions and eligibility criteria. However, businesses must still maintain appropriate documentation and demonstrate that the services qualify for simplified treatment under UAE Corporate Tax principles.
At thetransferpricing.com, we assist businesses with practical, technically robust, and commercially focused UAE Transfer Pricing solutions. Our services include:
- UAE Benchmarking Studies & Benchmarking Reports
- UAE Local File & Master File Preparation
- FAR Analysis
- Related Party & Connected Person Reviews
- Management Fee Analysis
- Arm’s Length Price Analysis
- UAE Transfer Pricing Health Checks
- Intercompany Agreement Reviews
- Transfer Pricing Policy Design
- UAE Corporate Tax TP Compliance Support
- Audit Readiness & Documentation Support
We support multinational groups, family-owned businesses, free zone entities, mainland companies, holding structures, shared service centers, and cross-border organizations operating in the UAE with practical and audit-ready transfer pricing solutions aligned with UAE regulatory expectations and internationally accepted transfer pricing principles.
Speak to a UAE Transfer Pricing Specialist
Disclaimer
The information contained on this page is intended for general informational and educational purposes only and should not be considered legal, tax, accounting, or professional advice. UAE Corporate Tax laws, Transfer Pricing regulations, and Federal Tax Authority guidance may evolve over time through legislative amendments, regulatory updates, and administrative interpretation. Businesses should seek professional advice tailored to their specific facts and circumstances before making Transfer Pricing or Corporate Tax decisions. thetransferpricing.com and Prime Partners Global do not accept responsibility for any reliance placed solely on the information presented on this page without obtaining professional consultation.