Transfer pricing support for UAE groups and related-party transactions

Under UAE Corporate Tax, transactions with related parties and connected persons must follow the arm’s length principle. We review your intercompany arrangements, prepare the disclosures filed with your return and build documentation that stands up if the FTA asks.

Arm’s length reviewDisclosure formMaster file and local fileIntercompany agreements

Our transfer pricing services

From a first health check to full documentation, scaled to the size and complexity of your group.

Transaction mapping

We identify related parties and connected persons and list every transaction type, such as services, financing, goods, royalties, management fees and cost recharges.

Arm’s length review

We test whether prices and terms match what independent parties would agree and recommend adjustments where they do not.

  • Method selection
  • Benchmarking support
  • Year-end adjustments

Disclosure form

We prepare the transfer pricing disclosure filed with your Corporate Tax return when your related-party transactions reach the reporting threshold.

Master file and local file

For businesses within the documentation thresholds, we prepare the master file and local file so they can be provided within 30 days of an FTA request.

Intercompany agreements

We review or draft agreements so the legal terms match how the transactions actually work.

Key thresholds at a glance

Thresholds that decide what you need to file or keep.

RequirementWhen it applies
Transfer pricing disclosure formRelated-party transactions totalling AED 40 million or more in the tax period
Master file and local fileUAE revenue of AED 200 million or more, or part of a multinational group with consolidated revenue of AED 3.15 billion or more
Documentation on requestProvided within 30 days of an FTA request
Arm’s length principleAll related-party and connected-person transactions, regardless of size

Thresholds are set by FTA decisions and may change. We confirm the current position for your tax period.

How we work

  1. 1

    Scoping

    We map your group and transactions and confirm which requirements apply.

  2. 2

    Analysis

    We review pricing, choose methods and benchmark where needed.

  3. 3

    Documentation

    We prepare disclosures, files and agreements.

  4. 4

    Ongoing support

    We help you apply the policy year to year and respond to FTA queries.

Common related-party transactions

  • Management and shared service fees
  • Intercompany loans and guarantees
  • Sale or purchase of goods within a group
  • Use of brands, IP or licences
  • Payments to owners, directors and their relatives

Why it matters

  • The FTA can adjust prices that are not at arm’s length
  • Adjustments can increase your taxable income
  • Missing documentation weakens your position in a review
  • Good policies reduce disputes and double taxation risk

Frequently asked questions

Does transfer pricing apply to small businesses?

The arm’s length principle applies to all businesses with related-party or connected-person transactions. The documentation and disclosure thresholds decide how much paperwork is required, not whether the rule applies.

Who counts as a connected person?

Broadly, owners, directors, officers and their related parties. Payments to them must reflect the market value of the service they provide.

When do I need a master file and local file?

When your revenue is AED 200 million or more, or you are part of a multinational group with consolidated revenue of AED 3.15 billion or more.

When is the disclosure form filed?

It is submitted with your Corporate Tax return when related-party transactions reach the reporting threshold.

Related services

Not sure whether transfer pricing applies to you?

Tell us how your group is structured and we will confirm what you need to file and keep.