Transfer Pricing
in the UAE
Comply with requirements, avoid penalties, and build a transparent tax strategy
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- The introduction of corporate tax in the UAE has made transfer pricing an essential part of tax compliance. Companies must not only maintain proper accounting but also be able to justify the prices of their intra-group transactions. We help you do this correctly and without unnecessary risks.Elena Varyukhina, Founder of Eagle EyeConsultant-methodologist in international tax planning, financial reporting, and business structuring, with over 15 years of experience
Key Transfer Pricing Requirements in the UAE
Transfer pricing regulates transactions between related parties and ensures that they are carried out at arm's length.
It is a mandatory part of tax compliance: without proper Transfer Pricing, a company risks facing reassessments and penalties.
It is a mandatory part of tax compliance: without proper Transfer Pricing, a company risks facing reassessments and penalties.
Transfer Pricing rules in the UAE are based on OECD principles and apply to all companies with related parties in the UAE or abroad. Particular attention is given to loans, intra-group services, licensing of intellectual property, and profit allocation within the group.
Transfer Pricing documentation is mandatory for companies with revenue exceeding AED 200 million or intra-group transactions above AED 40 million. Non-compliance may lead to fines, which is why it is crucial to prepare the Local file and Master file in advance, in line with FTA requirements and international standards.
Transfer Pricing documentation is mandatory for companies with revenue exceeding AED 200 million or intra-group transactions above AED 40 million. Non-compliance may lead to fines, which is why it is crucial to prepare the Local file and Master file in advance, in line with FTA requirements and international standards.
Why Compliance with Transfer Pricing Rules Is Essential
Mandatory documentation
Companies must maintain and, if requested, provide Transfer Pricing documentation for intra-group transactions (Local file, Master file).
Penalties for non-compliance
Breaches of Transfer Pricing rules may result in significant fines and additional tax assessments.
Business transparency
Proper Transfer Pricing reduces tax risks and demonstrates good faith during inspections.
0% corporate tax benefit
To apply the 0% corporate tax rate, Transfer Pricing documentation is a mandatory condition.
Our Transfer Pricing Services
We help companies comply with FTA requirements and OECD standards — from analyzing intra-group transactions to preparing documentation and defending your position during audits.
With us, you minimize tax risks, avoid penalties, and gain confidence that your corporate tax is calculated correctly.
With us, you minimize tax risks, avoid penalties, and gain confidence that your corporate tax is calculated correctly.
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Transaction analysisWe determine which intra-group operations fall under Transfer Pricing rules in the UAE -
Documentation preparationWe develop the methodology and assess transactions for arm’s length compliance -
TP reportingWe prepare the Local file and Master file, as well as the annual corporate tax return with Transfer Pricing elements for submission to the UAE Federal Tax Authority (FTA) -
Support during auditsWe help prepare responses to tax authority requests and defend the client’s position
How We Work with Transfer Pricing
Diagnosis and assessment
We analyze your request, company structure, and intra-group transactions. We identify which transactions fall under Transfer Pricing rules and prepare a detailed work plan with estimated timelines and costs.
Agreement and payment
We agree on the scope of work, sign the contract, and issue an invoice. Once the payment is processed, our team proceeds with the analysis and documentation.
Execution
We conduct functional and economic analysis, prepare the Local file and Master file, and apply OECD methods to test arm’s length compliance. All documents are prepared in line with Federal Tax Authority (FTA) requirements.
Support and defense
If necessary, we assist in preparing responses to tax authority requests, accompany the client during audits, and defend their position.
Get a free consultation on Transfer Pricing in the UAE
FAQ
No. The obligation depends on established thresholds: companies with annual revenue exceeding AED 200 million or intra-group transactions above AED 40 million must prepare a Local file and Master file. However, even companies below these thresholds should be ready to demonstrate that their related-party transactions are conducted at arm’s length.
The Local file describes the activities and related-party transactions of the UAE entity, including a functional analysis, transaction details, and applied pricing methods. The Master file provides a broader overview of the multinational group, outlining its structure, functions, assets, risks, and global allocation of income. Both must comply with OECD guidelines and UAE FTA requirements.
The UAE follows OECD guidance, allowing five main methods:
- Comparable Uncontrolled Price (CUP);
- Resale Price Method;
- Cost Plus Method;
- Transactional Net Margin Method;
- Profit Split Method.
- The method chosen depends on the type of transaction: CUP is common for loans, Cost Plus for intra-group services, and Profit Split for complex value chains.
Penalties in the UAE can be substantial. Failure to provide documentation or reports on time can result in fixed fines starting at AED 10,000 and higher, as well as additional tax reassessments. In some cases, the tax authority may recalculate transactions, increasing the corporate tax base.
Transfer Pricing is a new and complex area in the UAE. Consultants help companies determine which transactions are subject to the rules, select the correct method of analysis, prepare compliant documentation, and reduce the risk of errors or fines. This saves internal resources and ensures strong defense in case of an audit.
Transfer Pricing documentation must be ready at the time of filing the corporate tax return and submitted to the FTA within 30 days upon request. Companies are required to keep this documentation for at least five years. Starting preparation early—together with annual reporting—is strongly recommended.
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We aim to be your trusted partner, helping you achieve success in the international business environment through professionalism, innovation, and exceptional service.
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info@acceagleeye.com
Oh My Desk, Al Fattan Downtown, 32d St Al Satwa
Dubai, UAE
+971 52 552 9700
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