Expert Transfer Pricing Services in Dubai, UAE
Ensure your cross-border transactions meet arm’s length standards with expert Transfer Pricing solutions tailored for UAE businesses. At Dubai Business & Tax Advisors, we help you stay compliant with UAE transfer pricing regulations, optimize your structure for tax efficiency, and avoid costly penalties, all backed by UK-qualified advisors and global experience.
- 10+ Years Of Experience
- 1500+ Audit Completed
- Financial Experts
- 2500+ Consultation
Why Transfer Pricing Is Critical for Your Business
In today’s globalized economy, Transfer Pricing directly affects how profits, taxes, and risks are distributed across your group entities. Without a compliant transfer pricing in UAE framework, your business could face double taxation, regulatory disputes, or reputational risks. Establishing arm’s-length pricing ensures transparent transactions and safeguards your operations against unwanted audits.
Accurate financial transfer pricing also enhances group efficiency and cash-flow planning. From funds transfer pricing to business restructuring transfer pricing, properly documented intercompany policies improve liquidity and internal financing decisions, aligning with the UAE’s OECD-based transfer pricing rules.
By implementing a robust Dubai transfer pricing strategy, businesses not only ensure compliance but also unlock strategic benefits such as profit optimization and long-term tax certainty. It transforms compliance into a competitive advantage that supports sustainable global expansion.
Key Advantages:
- Reduce risk of transfer pricing adjustments and penalties
- Improve cross-border tax efficiency and group cash flow
- Strengthen financial governance and audit readiness
- Enhance investor confidence through transparent reporting
Our Scope in Transfer Pricing Services
With the UAE’s corporate tax framework now fully aligned with OECD standards, managing Transfer Pricing has become a crucial compliance area for every multinational and free zone company. Our team at Dubai Business & Tax Advisors provides strategic and practical guidance to help you price intercompany transactions accurately and stay fully compliant with UAE Ministry of Finance and OECD BEPS Action 13 requirements.
We go beyond documentation, offering end-to-end advisory, from financial transactions transfer pricing to business restructuring transfer pricing, ensuring your models reflect true economic substance, commercial rationale, and global consistency. Partner with us to future-proof your organization against audit risks while improving financial governance and profitability.
Transfer Pricing Services in Dubai
- Transfer Pricing Documentation (Master File & Local File)
- Benchmarking & Economic Analysis
- Transfer Pricing Policy Design & Implementation
- Funds & Liquidity Transfer Pricing Advisory
- Risk Assessment & Dispute Resolution Support
- Advance Pricing Agreement (APA) Assistance
- Business Restructuring & Intercompany Financing Advisory
- Transfer Pricing Audit Representation & Compliance Review
Why Dubai Business & Tax Advisors for Transfer Pricing in UAE?
At Dubai Business & Tax Advisors, we combine international tax expertise with UAE-specific knowledge to deliver end-to-end transfer pricing solutions. Our UK-qualified professionals and in-house tax specialists ensure compliance, risk mitigation, and tax efficiency across all intercompany transactions.
Key Benefits:
- Register & comply from anywhere in the UAE
- Access deep expertise & real-time advisory support
- Transparent process, pricing, and deliverables
- 100% compliance with UAE and OECD standards
Global Expertise, Local Insight
Our team has deep experience in financial transactions transfer pricing and business restructuring transfer pricing, ensuring that your UAE operations remain aligned with both OECD and FTA regulations.
Comprehensive Compliance Support
We guide you through every stage, from transfer pricing documentation and benchmarking to transfer pricing audit representation and dispute resolution, ensuring your business is always one step ahead of regulatory expectations.
Strategic Clarity
Our forward-looking approach helps transform compliance into strategic value, strengthening investor trust and supporting long-term global expansion.
Process of Ensuring Transfer Pricing Compliance in Dubai and the UAE
At Dubai Business & Tax Advisors, we simplify the complexities of transfer pricing compliance for UAE-based and international businesses. Our step-by-step approach ensures accurate documentation, effective planning, and complete adherence to the arm’s length principle, aligning with both UAE Corporate Tax and OECD standards.
Identify Related Party Transactions
The first step is recognizing all related-party and connected-person transactions across jurisdictions. This includes intercompany financing, liquidity transfer pricing, and shared services. Understanding the scope of these transactions is essential for accurate disclosure and risk mitigation.
Prepare and Maintain Documentation
We assist businesses in preparing the Local File, Master File, and Disclosure Form, ensuring every transaction meets transfer pricing documentation requirements. Proper documentation protects you during audits and demonstrates full compliance with UAE Ministry of Finance regulations.
Conduct Benchmarking & Analysis
Our team conducts in-depth benchmarking studies using reliable market data to determine arm’s length prices for financial transactions transfer pricing and funds transfer pricing. This ensures pricing reflects true economic value and minimizes the chance of adjustments by the Federal Tax Authority.
Develop or Update Transfer Pricing Policy
A strong transfer pricing policy is your defense against compliance risks. We help design and implement frameworks that guide intercompany pricing, support tax audits, and align with your broader business strategy and restructuring goals.
Manage TP Audits & Dispute Resolution
Our experts provide complete transfer pricing audit support, from managing inquiries to defending your pricing positions. We also assist with Advance Pricing Agreements (APA) and Mutual Agreement Procedures (MAP) to avoid double taxation and resolve disputes effectively.
What Damages Can Delaying Transfer Pricing Compliance Cause Your Business?
Delaying action on transfer pricing in UAE obligations may seem low risk, until audit season sparks a cascade of costly surprises. Procrastination doesn’t just invite penalties; it undermines your strategic footing, disrupts cash flows, and can even erode stakeholder trust over time.
You risk:
- Potential tax adjustments by authorities that increase your corporate tax base
- Loss of deductions or disallowance of intercompany expenses
- Double taxation if one jurisdiction adjusts your profits in its favor
- Reputational damage and diminished investor confidence
- Escalated audit scrutiny in future years
- Legal disputes, appeals, or prolonged transfer pricing audit processes
- Challenge in obtaining Advance Pricing Agreements (APAs)
- Disrupted business restructuring plans due to retroactive adjustments
Once a tax authority audits you, they may impose adjustments retroactively, requiring you to restate past profits, pay back taxes, interest, and face administrative fines. Without robust transfer pricing documentation in hand, you lose defensive positioning and may have to contest aggressive adjustments from a disadvantaged posture.
Let’s Get Started with Your Transfer Pricing Compliance
If you’re looking for expert assistance with transfer pricing in UAE, our qualified transfer pricing consultants in Dubai are here to manage the entire process, from documentation to audit defense, ensuring your compliance is effortless and precise.
Why Choose DBTA:
- Expert transfer pricing advisors with UK and UAE experience
- We handle the whole process for you, from policy design to reporting
- Peace of mind knowing your transfer pricing documentation meets FTA standards
- Tailored support for financial transactions transfer pricing and business restructuring transfer pricing
- Transparent process, pricing, and deliverables at every stage
Our team ensures your transfer pricing audit and reporting are completed on time and in line with OECD and UAE Ministry of Finance requirements. Every detail is handled meticulously, so your business can operate confidently within the UAE’s evolving tax landscape.
Partner with Dubai Business & Tax Advisors today to safeguard your global operations and strengthen compliance, while keeping your focus on growth, not paperwork.
FAQs – Corporate Tax in Dubai
What is transfer pricing?
Transfer pricing refers to the valuation of transactions between entities under common control. It ensures that intercompany transfers of goods, services, financing or intangibles are priced as if between independent parties. Its purpose is to prevent profit shifting and maintain fairness in taxation across jurisdictions.
Who are related parties or connected persons?
Related parties or connected persons include entities or individuals linked by common ownership, control, influential shareholding, or kinship. The UAE law defines specific thresholds and relationships for determining connected persons beyond mere ownership, including directors and certain family members.
Why does transfer pricing matter for UAE businesses?
Transfer pricing matters because it ensures compliance, reduces risk of tax adjustments, and preserves deductions. Inaccurate or unsupported pricing may lead to audit scrutiny, adjustments in taxable income, penalties, and reputational damage. It also aligns your operations with global standards.
Which kinds of transactions fall under transfer pricing rules?
Transactions such as intercompany sales, management services, licensing of intangibles, intra-group loans, cost recharges, guarantees, royalties, and shared services fall under transfer pricing rules when conducted between related parties. Any controlled transaction that influences group profit allocation typically qualifies.
What is the arm’s length principle?
The arm’s length principle requires that any transaction between related parties be conducted under the same terms and pricing as would apply between independent, unrelated parties under comparable circumstances. It ensures fairness, prevents manipulation of profits, and underpins defensible tax positions under audit.
Is benchmarking required for transfer pricing?
Yes. Benchmarking is essential to support that your intercompany pricing is consistent with market comparables. It involves selecting comparable independent transactions or entities and adjusting for differences to validate that your related-party pricing falls within an acceptable range.
When is the disclosure form required?
The transfer pricing Disclosure Form is required when a business’s aggregate related party transactions exceed AED 40 million. In such cases, detailed schedules by category also must be submitted with the corporate tax return.
Do domestic UAE transactions also come under TP rules?
Yes. Transactions between related parties located wholly within the UAE are within the scope of the transfer pricing regime. The rules do not just apply to cross-border dealings; domestic intercompany arrangements must also adhere to the arm’s length principle.
Are all businesses required to maintain transfer pricing documentation?
No. Only those meeting certain thresholds (such as revenue over AED 200 million or being part of a group with consolidated revenue over AED 3.15 billion) must prepare full TP documentation (Local File, Master File). Others may still need to support their pricing under the arm’s length principle.
What is a Master File versus a Local File?
A Master File provides a global overview of the multinational group’s operations and transfer pricing policies. The Local File is focused on the domestic entity’s controlled transactions, detailing functional, financial, and comparability analyses to support arm’s length pricing.
What triggers the AED 200 million threshold?
The AED 200 million threshold applies when a taxable person’s revenue in the relevant tax period reaches or exceeds that amount. Meeting this threshold typically obliges preparation of full TP documentation, such as Local File and Master File.
When does the AED 3.15 billion group threshold matter?
When a business is part of a multinational group whose consolidated global revenue equals or exceeds AED 3.15 billion, the group must meet TP documentation obligations, including preparing Master File and Local File for constituent entities.
What is the AED 40 million threshold for disclosure?
If aggregate related party transactions exceed AED 40 million, the business must complete the related party schedule in its tax return. Additionally, only transaction categories above AED 4 million require detailed disclosure.
Do individual transaction categories have separate thresholds?
Yes. Even when aggregate related party dealings cross AED 40 million, detailed disclosure is needed only for categories (goods, services, interest, IP, etc.) whose aggregated value exceeds AED 4 million.
When is only a Local File required?
If a taxpayer does not cross the global group threshold (AED 3.15 billion) but meets local revenue or transaction thresholds, they might only need to maintain a Local File, without a Master File, depending on group structure and domestic operations.
Are Free Zone entities exempt from TP rules?
No. Even Free Zone entities remain subject to TP rules if they transact with related parties. They must comply with the arm’s length principle and maintain supporting documentation to retain tax benefits.
Do all intra-group transactions within a tax group require TP documentation?
No. If entities are consolidated into a UAE Tax Group, internal transactions among those group members may be eliminated for TP purposes and may not require separate TP documentation.
Is Small Business Relief a full exemption from TP?
Small Business Relief may exempt small entities from preparing full TP documentation (Local & Master Files), but it does not exempt them from applying the arm’s length principle to their intercompany transactions.
Do dividend payments count toward TP thresholds?
No. Dividends between related parties are excluded when calculating thresholds for the related party schedule (AED 40 million) and per-category disclosure (AED 4 million).
What is the effect of failing to meet thresholds?
Entities below thresholds are not required to comply with full documentation obligations, but they must still price related party transactions at arm’s length and may be called on to provide documentation in certain instances.
Which TP methods does UAE law accept?
UAE law allows all five OECD-recognized transfer pricing methods: Comparable Uncontrolled Price (CUP), Resale Price, Cost Plus, Transactional Net Margin Method (TNMM), and Profit Split. Alternative methods can be used with supporting justification.
When is CUP preferable to TNMM?
CUP is preferable when comparable uncontrolled transactions closely match your intercompany terms and risk profile. If reliable direct comparables are unavailable, TNMM may be more appropriate as it relies on net margin comparability.
Can you blend multiple methods?
Yes. One may use a combination of methods or a “middle ground” approach when no single method offers adequate comparability. The choice should be justified in the documentation to ensure defensibility.
How often should benchmarking be updated?
Benchmarking should be reviewed and refreshed annually or when significant business events occur (such as restructuring, market changes or major transactions). This ensures comparability remains valid and reliable.
How to select appropriate comparables?
Comparables are selected based on functional similarity, risk, geography, size, contractual terms and financial metrics. Differences should be adjusted to improve alignment and reflect comparable conditions.
What is the tested party concept?
The tested party is the entity chosen as the benchmark focus in the comparability analysis. It is typically the one whose financial data, functions, and risks are most reliably benchmarked against comparable independent entities.
How to adjust for comparability differences?
Adjustments may include accounting policy alignment, working capital, scale, risk, geographic and timing differences. These adjustments improve the comparability of benchmark data to your tested entity.
What is the profit split method?
The profit split method allocates combined profits or losses between related parties based on their relative contributions using cost, sales or value drivers. It is often used for complex transactions involving intangibles or integrated services.
How to document method selection logic?
Your documentation should clearly explain why a method was chosen over alternatives. It must include the functional analysis, comparability assessment, sensitivity tests, and narrative support to justify your decision under audit.
Does restructuring require new TP models?
Yes. Where business restructuring occurs, the functional, risk and comparability profile may change. Hence, new TP models, updated benchmarking and revised documentation are required to reflect the revised group structure.
What might trigger a TP audit in UAE?
Triggers include unusually low or high margins compared to industry norms, incomplete disclosures, absent or weak documentation, large related party transactions, and inconsistencies in comparability or benchmarking.
What risks result from delaying TP compliance?
Delaying compliance invites tax adjustments, disallowed deductions, fines, interest, double taxation, reputational damage, and weaker audit defense positions. It can destabilize cash flow and expose the business to retrospective corrections.
How to prepare for a TP audit?
Ensure contemporaneous documentation, maintain benchmarking studies, board approvals and internal memos. Be ready to explain your transfer pricing policies, adjustments, and comparability logic. Having clear, defensible files is key.
What penalties exist for noncompliance?
Penalties under Cabinet Decision 75 of 2023 include fines of AED 10,000 for a first violation, increasing to AED 20,000 for repeated violations within 24 months. Noncompliance may also lead to denied deductions or tax base adjustments.
What is a corresponding adjustment?
A corresponding adjustment is relief a taxpayer may request from the FTA if a foreign authority makes a transfer pricing adjustment. It aims to avoid double taxation by aligning the UAE taxable income accordingly, under treaty provisions.
What is an Advance Pricing Agreement (APA)?
An APA is a binding agreement between a taxpayer and one or more tax authorities to agree in advance on the transfer pricing method for particular transactions, thus minimizing future audit disputes and uncertainties.
What is MAP (Mutual Agreement Procedure)?
MAP is a mechanism under bilateral or multilateral treaties allowing tax authorities to resolve transfer pricing disputes and avoid double taxation by negotiating adjustments consistent with the arm’s length principle
Can TP adjustments be contested?
Yes. Taxpayers may contest FTA TP adjustments via appeal processes, provide supplementary evidence, invoke MAP under treaties, or pursue arbitration depending on applicable tax treaties and dispute resolution mechanisms.
How long should TP records be retained?
Typically, TP records, documentation, and supporting files should be retained for at least seven years following the end of the tax period to satisfy FTA audit requests or inquiries.
Can TP be applied retroactively?
Yes. The FTA may make retrospective adjustments for years where controlled transactions were not priced at arm’s length. Businesses must maintain sufficiently robust documentation to defend or negotiate adjustments.
Our clients, ranging from startups to multinational corporations in Dubai, benefit from our comprehensive and strategic approach to business advisory. Our team of highly qualified business and tax advisors takes pride in ensuring regulatory compliance, operational efficiency, and sustainable long-term success for businesses across various industries
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