Transfer Pricing Services in UAE

The implementation of UAE Corporate Tax and the deployment of OECD-aligned transfer pricing rules have increased compliance and documentation obligations for many businesses operating in the UAE. Transfer pricing is now a key focus area for tax authorities, requiring robust policies, defensible pricing methodologies, and comprehensive documentation.

We provide transfer pricing advisory services in Abu Dhabi, Dubai, Sharjah and other parts of UAE, supporting multinational enterprises, regional headquarters, and UAE-based groups in managing intercompany transactions in accordance with UAE Corporate Tax Law and OECD Transfer Pricing Guidelines.

What is transfer pricing?

Our transfer pricing advisory services in the UAE are designed to help businesses establish, review, and elaborate transfer pricing frameworks that reflect the arm’s length principle and align with commercial reality. We assist clients throughout the transfer pricing lifecycle, from policy design to implementation and ongoing review, ensuring consistency across financial, tax, & operational functions.

Our advisory offerings include:

Development and review of group-wide transfer pricing policies
Functional, Asset, and Risk (FAR) analysis
Value chain and business model analysis
Selection and application of appropriate transfer pricing methods
Economic benchmarking and comparability studies
Pricing support for complex and high-risk transactions

Our approach is aligned with OECD standards while tailored to the specific requirements of the UAE Corporate Tax regime.

We support businesses in structuring and documenting related-party transactions across jurisdictions.

Intercompany Transactions in Transfer Pricing

We advise on a wide range of intercompany arrangements, including:

Management and support service fees
Royalty and intellectual property arrangements
Cost contribution and cost-sharing arrangements
Intercompany financing and guarantees
Information Technology services
Software services
Distribution, manufacturing, and procurement structures

Our Dubai and UAE intercompany transfer pricing consulting services focus on ensuring that intercompany pricing reflects economic substance, is commercially defensible, and withstands regulatory scrutiny during audits and enquiries.

Intercompany transactions are a key focus area under the UAE Corporate Tax regime and OECD Transfer Pricing Guidelines. Any transaction entered into between related parties or connected persons must be priced in accordance with the arm’s length principle, ensuring that the outcome is consistent with what independent parties would have agreed under comparable circumstances.

With increased regulatory scrutiny, businesses operating in Abu Dhabi, Dubai, Sharjah, Ras Al Khaimah are required to identify, analyze, price, and document their intercompany transactions in a robust and defensible manner.

a. Common Types of Intercompany Transactions

Intercompany transactions subject to transfer pricing rules in the UAE typically include, but are not limited to:

Management and administrative services
Technical, support, and shared services arrangements
Royalty and intellectual property licensing
Information Technology services
Software related services
Intercompany financing, loans, and guarantees
Cost contribution and cost-sharing arrangements
Sale and purchase of goods between related entities
Distribution, commission, and agency arrangements

Each category of transaction carries unique transfer pricing risks and requires careful evaluation of the underlying functions performed, assets employed, and risks assumed by the parties involved.

b. Arm’s Length Pricing of Intercompany Transactions

To comply with UAE transfer pricing requirements, intercompany transactions must be priced using appropriate OECD-recognized transfer pricing methods. This involves:

Conducting a detailed Functional, Asset, and Risk (FAR) analysis
Identifying the economically significant activities performed by each entity
Selecting the most appropriate transfer pricing method
Performing benchmarking and comparability analyses
Establishing defensible pricing mechanisms supported by economic evidence

ANBAC Advisors assists clients in structuring and pricing intercompany transactions in a manner that reflects commercial reality while remaining compliant with UAE Corporate Tax regulations

Transfer Pricing Documentation and Compliance

Transfer pricing documentation is a core compliance obligation under the UAE Corporate Tax framework. Proper documentation demonstrates that intercompany transactions are conducted at arm’s length and provides a defensible position in the event of tax authority reviews or audits.

Transfer Pricing Compliance and Documentation

We offer end-to-end transfer pricing compliance and documentation services in Dubai, helping clients meet statutory requirements under UAE Corporate Tax regulations.

Our compliance and documentation services include:

Preparation of Master File and Local File documentation
Support for transfer pricing disclosures and reporting obligations
Review and remediation of existing transfer pricing documentation
Alignment of legal agreements with transfer pricing policies
Audit defence and support during tax authority reviews

We prepare holistic documentation that is accurate, consistent, and contemporaneous, reducing the risk of penalties, adjustments, and disputes.

Transfer Pricing Documentation Requirements

Under the UAE Corporate Tax Law and Ministerial Decision No. 97 of 2023, certain businesses must maintain detailed transfer pricing documentation.

a) Master File

Required if:

The multinational group’s consolidated revenue is AED 3.15 billion or more, or
The UAE entity’s revenue is AED 200 million or more

The Master File provides a global overview of the group’s business, value chain, and transfer pricing policies.

b) Local File

Required for the same thresholds as above. The Local File focuses on the UAE entity and includes transaction analysis, FAR analysis, and benchmarking studies.

Businesses operating in the UAE may be required to maintain the following documentation:

Document Type Purpose Key Contents

Document Type	Purpose	Details
Master File	Provides a high-level overview of the multinational group	• Group organizational structure • Description of the group’s business and value chain • Group transfer pricing policies • Intangible assets and intellectual property ownership • Intercompany financing arrangements
Local File	Focuses on the UAE entity and its transfer pricing position	• Detailed description of local business operations • Analysis of material intercompany transactions • Functional, asset, and risk analysis of the UAE entity • Economic benchmarking and pricing analysis • Financial information supporting transfer pricing outcomes

Document Type

Purpose

Details

Master File

Provides a high-level overview of the multinational group

• Group organizational structure

• Description of the group’s business and value chain

• Group transfer pricing policies

• Intangible assets and intellectual property ownership

• Intercompany financing arrangements

Local File

Focuses on the UAE entity and its transfer pricing position

• Detailed description of local business operations

• Analysis of material intercompany transactions

• Functional, asset, and risk analysis of the UAE entity

• Economic benchmarking and pricing analysis

• Financial information supporting transfer pricing outcomes

Even where formal filing thresholds are not met, maintaining contemporaneous documentation is considered best practice and significantly reduces compliance risk.

When Must Transfer Pricing Documentation Be Submitted?

Transfer pricing documentation is not filed automatically with the tax return
Documents must be maintained contemporaneously

The FTA may request documents during an audit, typically to be submitted within 30 days

Transfer Pricing Compliance Regulations in the UAE

Transfer pricing compliance in Dubai extends beyond documentation preparation. Businesses are expected to ensure ongoing alignment between transfer pricing policies, legal agreements, and actual operational conduct.

Key compliance considerations include:

Accurate identification and disclosure of related-party transactions
Consistency between intercompany agreements and transfer pricing outcomes
Annual review and update of transfer pricing documentation
Alignment with UAE Corporate Tax filings and financial statements
Readiness to respond to tax authority audits and enquiries

Failure to comply with transfer pricing requirements may result in penalties, tax adjustments, and increased audit exposure.

With the introduction of Corporate Tax in the UAE, transfer pricing regulations have become a key compliance requirement for businesses engaged in related-party transactions. The UAE transfer pricing framework aligns closely with OECD Transfer Pricing Guidelines, making it essential for companies to review their intercompany arrangements.

A. What Are Transfer Pricing Regulations in the UAE?

UAE transfer pricing regulations require businesses to ensure that transactions between related parties and connected persons are conducted at arm’s length. This means pricing must reflect what independent parties would agree under similar circumstances.

These rules apply to both cross-border and domestic transactions and are enforced by the Federal Tax Authority (FTA).

B. Who Needs to Comply With UAE Transfer Pricing Rules?

You must comply with UAE transfer pricing regulations if your business:

Is subject to UAE Corporate Tax
Engages in transactions with related parties or connected persons
Operates as part of a multinational group or local group structure

Even businesses that do not meet documentation thresholds must still apply arm’s length pricing.

C. What is Arm’s Length Principle Under UAE Transfer Pricing Law?

The Federal Decree-Law No. 47 of 2022, issued on 3 October 2022, on the Taxation of Corporations and Businesses (UAE CT Law) by Ministry of Finance (MoF) consists of specific provisions for Transfer Pricing (TP) which provides guidance on the coverage as well as the application of the Arm’s Length Principle. The arm’s length principle is the foundation of UAE transfer pricing regulations. Businesses must:

Select the most appropriate transfer pricing method
Conduct functional, asset, and risk (FAR) analysis
Support pricing with economic benchmarking

Failure to apply the arm’s length principle can lead to tax adjustments and penalties.

D. What is Transfer Pricing Disclosure Form in the UAE?

Businesses exceeding prescribed thresholds must submit a Transfer Pricing Disclosure Form along with their Corporate Tax return. This form captures:

Related-party relationships
Nature and value of intercompany transactions
Transfer pricing methods applied

This disclosure increases transparency and audit scrutiny.

E. Who is required to conduct Country-by-Country Reporting (CbCR) in the UAE?

Country-by-Country Reporting applies to multinational groups with consolidated revenue of AED 3.15 billion or more. It provides tax authorities with a global snapshot of income, taxes, and economic activity.

F. What are the Penalties and Risks for Non-Compliance?

Non-compliance with UAE transfer pricing regulations can result in:

Corporate tax adjustments
Administrative penalties
Increased audit exposure
Reputational risk with tax authorities

Proper transfer pricing compliance significantly reduces these risks.

G. How can we have reliable Audit Defence and Risk Management?

With the UAE tax authorities expected to increase focus on transfer pricing, audit readiness is critical. Robust documentation, clear pricing logic, and consistent implementation significantly strengthen a taxpayer’s defence position.

We support clients with:

Transfer pricing audit and enquiry support
Review and remediation of legacy documentation
Preparation of technical defence files and position papers
Assistance in responding to information requests and assessments

Our approach is proactive, risk-focused, and aligned with international best practices.

Industry Experience and Practical Focus

Our transfer pricing consultants in UAE bring experience across a broad range of industries, including:

Financial services
Technology and digital businesses
Trading and distribution groups
Manufacturing and logistics
Professional services and holding structures

We combine technical expertise with a practical understanding of business operations to deliver solutions that are both compliant and commercially viable.

Why should you prefer ANBAC Advisors?

Deep understanding of UAE Corporate Tax and transfer pricing regulations
OECD-aligned methodologies and documentation standards
Practical, risk-focused advisory approach
Experience supporting multinational and regional group structures
Integrated support across tax, accounting, and regulatory matters

Whether you require strategic transfer pricing advisory services in Dubai, Abu Dhabi, Sharjah or specialized Dubai intercompany transfer pricing consulting, or comprehensive transfer pricing compliance and documentation in Dubai, ANBAC Advisors provides reliable and defensible solutions.

Frequently Asked Questions (FAQs)

a. What are transfer pricing advisory services in the UAE?
Transfer pricing advisory services in the UAE help businesses design, implement, and review intercompany pricing policies to ensure compliance with UAE transfer pricing regulations and OECD guidelines. These services assist multinational groups in managing transfer pricing risks and maintaining tax efficiency.

b. Who needs transfer pricing advisory services in the UAE?
Any business in Dubai, Abu Dhabi, Sharjah or other parts of UAE that engages in related-party or intercompany transactions, including cross-border dealings, may require transfer pricing advisory services to ensure transactions are conducted at arm’s length and comply with local regulations.

c. What is Dubai intercompany transfer pricing consulting?
Dubai intercompany transfer pricing consulting involves reviewing and analyzing transactions between related entities to confirm that pricing is consistent with the arm’s length principle. This includes functional, asset, and risk analysis, transaction evaluation, and selection of appropriate transfer pricing methods.

d. Why is intercompany transfer pricing consulting important in Dubai?
Intercompany transfer pricing consulting in Dubai helps businesses reduce tax and audit risks, maintain regulatory compliance, and ensure consistency in pricing across group entities, especially in light of increasing scrutiny by tax authorities.

e. What is transfer pricing compliance and documentation in Dubai?
Transfer pricing compliance and documentation in Dubai involve preparing and maintaining documents such as the Master File and Local File, along with benchmarking studies and financial analyses, to support intercompany pricing arrangements.

f. Is transfer pricing documentation mandatory in Dubai?
Transfer pricing documentation may be mandatory depending on thresholds and regulatory requirements. However, even when not legally required, maintaining proper documentation is considered best practice and significantly reduces compliance and audit risks.

g. What documents are included under transfer pricing compliance in Dubai?
Transfer pricing compliance documentation typically includes a Master File, Local File, economic benchmarking studies, intercompany agreements, and financial information supporting transfer pricing outcomes.

h. How do transfer pricing services help during a tax audit in the UAE?
Transfer pricing services help businesses defend their intercompany pricing during tax audits by providing robust documentation, clear economic analysis, and compliance with UAE transfer pricing regulations and international standards.

Real-World Transfer Pricing Solutions for UAE & Dubai Businesses

a) Transfer Pricing Advisory Services – Case Study

Client Profile
A multinational group operating in the trading and distribution sector, with its regional headquarters in the United Arab Emirates and multiple related-party transactions across Asia and the Middle East.

Challenge
Following the introduction of UAE Corporate Tax, the client faced increased scrutiny on its intercompany pricing arrangements. The group did not have a documented transfer pricing policy aligned with UAE regulations and OECD guidelines, exposing it to compliance and audit risks.

Our Transfer Pricing Solution
We provided comprehensive transfer pricing advisory services in the UAE, including:

Review of existing intercompany transactions
Functional, asset, and risk (FAR) analysis
Selection of appropriate transfer pricing methods
Economic benchmarking to support arm’s length pricing

Outcome
The client successfully implemented a robust transfer pricing framework aligned with UAE regulations. This ensured arm’s length pricing, strengthened audit defensibility, and reduced future compliance risks under the UAE Corporate Tax regime.

b) Dubai Intercompany Transfer Pricing Consulting – Compliance & Documentation Case Study

Client Profile
A Dubai-based services company that is part of an international group, engaging in management fees, service charges, and cost-sharing arrangements with related entities.

Challenge
The client was required to meet transfer pricing compliance and documentation requirements in Dubai, including preparation of Local File documentation. The company faced tight deadlines and lacked internal expertise to meet regulatory expectations.

Our Transfer Pricing Solution
Our team delivered end-to-end Dubai intercompany transfer pricing consulting, covering:

Detailed analysis of intercompany transactions
Functional, asset, and risk analysis of the Dubai entity
Preparation of Local File documentation
Economic benchmarking and pricing analysis in line with UAE regulations

Outcome
The client achieved timely and complete transfer pricing compliance and documentation in Dubai, ensuring readiness for any Federal Tax Authority review. The documentation significantly reduced audit exposure and strengthened the company’s overall tax governance framework.

Looking for transfer pricing advisory services in the UAE or Dubai?

We help businesses manage intercompany pricing, documentation, and compliance with UAE Corporate Tax regulations. Speak to our transfer pricing specialists today.