Transfer pricing is an important part of UAE Corporate Tax compliance for businesses conducting transactions with related parties and connected persons. Peter Morrison provides transfer pricing advisory covering arm’s length analysis, benchmarking, documentation and ongoing compliance support for businesses operating in the UAE.
What Is Transfer Pricing?
Clear Transfer Pricing Guidance for UAE Businesses
Our Transfer Pricing Services
We support businesses with the analysis, documentation and ongoing review required for related-party transactions. Our services can be tailored to the nature of your transactions, business structure and applicable UAE transfer pricing requirements.
Transfer Pricing Regulations in the UAE
Who Needs to Consider Transfer Pricing in the UAE?
The Arm’s Length Principle
Transfer Pricing Methods
Comparable Uncontrolled Price Method
Resale Price Method
Cost Plus Method
Transactional Net Margin Method (TNMM)
Profit Split Method
Safeguard your global operations with robust transfer pricing strategies.
- Our approach
Compliance at Its Core
1. Functional & Risk Analysis
We examine the functions performed, assets used and risks assumed by the parties involved to establish the economic basis for the transfer pricing analysis.
2. Benchmarking & Comparability Analysis
We identify relevant comparable transactions or companies and assess the available data to support an arm’s length outcome.
3. Transfer Pricing Documentation
We assist with relevant transfer pricing documentation, including the analysis and supporting information required for applicable compliance obligations.
4. Ongoing Transfer Pricing Advisory
We review changes in business structures, related-party transactions and operating arrangements that may affect transfer pricing policies and documentation.
Review Your Transfer Pricing Requirements
Speak with Peter Morrison about your UAE transfer pricing, benchmarking and documentation requirements.
Frequently Asked Questions About Transfer Prices Services in UAE
Transfer pricing refers to the pricing of transactions between related parties and connected persons, such as associated companies or businesses under common ownership. Under UAE Corporate Tax law, these transactions must follow the arm’s length principle, meaning prices and terms should reflect those agreed between independent parties under comparable circumstances.
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UAE transfer pricing regulations are governed by Federal Decree-Law No. 47 of 2022, as amended. Article 34 requires related-party and connected-person transactions to meet the arm’s length standard. The Federal Tax Authority (FTA) provides additional guidance on compliance, pricing methods and documentation requirements under the UAE Corporate Tax framework.
The UAE transfer pricing guidelines explain how businesses should apply the arm’s length principle to related-party transactions. The FTA Transfer Pricing Guide (CTGTP1) discusses recognised methods, including Comparable Uncontrolled Price, Resale Price, Cost Plus, Transactional Net Margin and Profit Split, alongside comparability analysis and documentation requirements.
Businesses in Dubai may need transfer pricing documentation depending on their revenue, group structure and related-party transactions. A Master File and Local File are generally required where annual revenue reaches AED 200 million or the business belongs to a multinational group with consolidated revenue of at least AED 3.15 billion. Other businesses may still need supporting records.
Depending on applicable requirements, UAE businesses may need related-party and connected-person disclosures, a Local File, a Master File and supporting benchmarking analyses. Certain multinational groups may also have Country-by-Country Reporting (CbCR) obligations. The documentation required depends on the business’s transactions, revenue, group structure and relevant thresholds.
Transfer pricing benchmarking compares prices, profit margins or other financial indicators from related-party transactions with those of comparable independent transactions or businesses. It helps determine whether intercompany pricing follows the arm’s length principle and provides supporting evidence for UAE Corporate Tax compliance and transfer pricing documentation.
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UAE transfer pricing rules apply to relevant transactions between related parties and connected persons, including both domestic and cross-border arrangements. Examples include intercompany loans, management fees, shared services, sales of goods, intellectual property licensing and certain payments to owners or directors. These transactions must satisfy applicable arm’s length requirements.
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Ensure transfer pricing compliance with documentation and benchmarking.
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