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Transfer Pricing
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Transfer Pricing in UAE
With the introduction of the UAE Corporate Tax (CT) system under Federal Decree-Law No. 47 of 2022, businesses in Dubai and across the UAE must adhere to strict transfer pricing regulations. These rules, announced by the Ministry of Finance (MoF) in December 2022, require businesses to apply the arm’s length principle in transactions between related parties.
This ensures that intercompany transactions are priced fairly, preventing tax avoidance and promoting transparency.
The Federal Tax Authority (FTA) enforces these transfer pricing guidelines, and compliance is now a crucial aspect of doing business in the UAE. To help businesses meet these new requirements, the MoF issued Ministerial Decision No. 97 of 2023 on May 11, which details how companies must prepare and maintain transfer pricing documentation. This law applies to all UAE businesses, including those operating within free zones.
At Bestax, we’re all about providing the best transfer pricing services in UAE. We help businesses like yours go through corporate tax rules very smoothly. Especially when dealing with inter-company transactions, whether they’re local or international.
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Transfer Pricing Compliance Process
01
Identify Related-Party Transactions
The first step involves reviewing all transactions with related parties and connected persons, both within and outside the UAE. These may include intercompany sales, management fees, intellectual property charges, financing arrangements, or cost-sharing agreements.
02
Select the Right Method
The UAE requires that related-party transactions be priced at arm’s length, meaning they should reflect conditions that would apply between independent parties. To determine this, businesses must select the most appropriate transfer pricing method from recognized approaches.
03
Conduct Benchmarking Analysis
A benchmarking study is conducted to test whether the selected method results in an arm’s length outcome. This involves identifying comparable companies, financial data, or market prices that support the pricing of intra-group transactions.
04
Prepare Documentation
To meet compliance requirements under UAE Corporate Tax Law, businesses must prepare all documentation. This documentation must be ready to present upon request by the Federal Tax Authority (FTA).
05
Submit Reports
Companies must disclose related-party transactions in their corporate tax return. In some cases, additional transfer pricing forms may be required, depending on transaction thresholds or FTA requirements. Timely and accurate submission is essential to remain compliant.
06
Audit Support & Dispute Resolution
In the event of a tax audit or FTA inquiry, businesses must be prepared to defend their transfer pricing policies and documentation. Our services include audit support, negotiation with tax authorities, and dispute resolution to mitigate risks of adjustments or penalties.
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Our Transfer Pricing Services in UAE
Our team helps businesses stay fully compliant with UAE tax laws while streamlining operations. Below are the key services we offer to support your transfer pricing needs:
We handle all the necessary documentation for related-party transactions to ensure full compliance with UAE tax regulations. Our documentation services include:
Master File: A detailed report outlining your group’s transfer pricing policies and global operations.
Local File: A comprehensive report focused on transactions carried out within the UAE, meeting all local compliance requirements.
Annual Transfer Pricing Reporting (Form 232): Filing the required annual report to ensure your business complies with UAE tax laws.
We strictly follow OECD guidelines and UAE laws to help you stay compliant without unnecessary hassle.
Our experts work with businesses to design and implement transfer pricing policies that suit your specific operations. We ensure:
Compliance with the Arm’s Length Principle: Guaranteeing that intercompany transactions are priced fairly.
Correct Application of OECD Methods: Ensuring the correct use of globally recognized transfer pricing methods.
Policy Adaptation & Implementation: Assisting you in adapting and applying new transfer pricing policies as required by changing laws and business needs.
Whether you’re a local business or part of a multinational group, we provide transfer pricing advisory services that ensure compliance and optimize your tax position.
For businesses looking for certainty in their transfer pricing policies, we manage Advanced Pricing Agreements (APAs). These agreements help define fair transfer pricing for cross-border transactions, reducing tax risks and avoiding future disputes. We assist with:
Unilateral APAs: Agreements with one tax authority.
Bilateral APAs: Agreements with two tax authorities.
Multilateral APAs: Agreements with multiple tax authorities.
With an APA in place, you minimize tax uncertainties and ensure compliance with UAE regulations.
We conduct thorough risk assessments to identify potential transfer pricing risks within your operations. Our team helps design strategies to mitigate these risks, ensuring that your intercompany pricing and transactions are compliant and efficient. We provide insights on:
Identifying high-risk areas in your transfer pricing policies.
Implementing strategies to minimize tax exposure and regulatory risks.
Optimizing your tax position by ensuring adherence to international guidelines.
In the event of a tax audit or dispute, we provide comprehensive support to defend your transfer pricing positions. Our services include:
Tax Audits: Ensuring your documentation is robust and supports your transfer pricing practices.
Tax Appeals: Offering expert guidance if tax authorities challenge your transfer pricing positions.
Mutual Agreement Procedures (MAPs): Assisting in resolving international tax disputes when issues arise between tax jurisdictions.
With Bestax’s expertise, you can be confident that you’ll be prepared for any audit or tax challenge.
Even if your business operates within a UAE free zone, transfer pricing rules still apply. We provide specialized services to ensure that free zone companies maintain the necessary documentation and meet all compliance requirements. Our team helps you:
Maintain local and master files specific to your operations in free zones.
Ensure transfer pricing practices are in line with UAE regulations and international standards.
Avoid penalties and audits by staying ahead of regulatory changes.
Our Other Services
We provide a full range of business and tax solutions to help you set up, stay compliant, and grow in the UAE.
See What Others Say About Us
At Bestax, we believe our work speaks for itself, but our clients speak even louder. Businesses across Dubai and the UAE trust us for accounting and bookkeeping services that are accurate, timely, and compliant with local laws.
Frequently Asked Questions
Frequently Asked Questions What are transfer pricing service fees in the UAE?
Fees vary by transaction complexity and documentation needs, covering benchmarking, compliance, and audit support.
What does a transfer pricing consultant do in the UAE?
They ensure compliance by selecting pricing methods, preparing documentation, and supporting audits or APAs.
What are the five transfer pricing methods in the UAE?
Per OECD: CUP compares prices; RPM deducts margins; CPM adds cost mark-ups; TNMM assesses net margins; PSM splits profits.
What are UAE transfer pricing documentation requirements?
Maintain a Master File, Local File, and annual Disclosure Form for related-party transactions.
What is the UAE transfer pricing disclosure form?
A form summarizing related-party transactions, mandatory for businesses exceeding AED 40 million in such dealings.
How can I prepare for a transfer pricing audit in the UAE?
Keep accurate documentation, align pricing with arm’s length principle, and conduct benchmarking studies.
Is transfer pricing applicable to all UAE businesses?
Exempt entities, standalone firms, and small businesses under relief may not require detailed documentation.









