Tax Agency Number (TAN) 30004113

Transfer Pricing Services Dubai

FTA Tax Agent TAN 30004113
DMCC Approved Auditor Account #148497
ICV Auditor Municipality Approved
30+ Years Established 1994

What is transfer pricing and when does it apply to UAE businesses?

Transfer pricing refers to the prices charged for transactions between related parties — such as between a UAE company and its parent, subsidiary, or affiliated entities. Under UAE Corporate Tax law, all related-party transactions must comply with the arm's length principle, priced as if the parties were independent. UAE businesses with revenue exceeding AED 200 million, or with related-party transactions above certain thresholds, must prepare formal transfer pricing documentation including a Local File and Master File, and complete the TP Disclosure Form in their annual Corporate Tax return filed with the Federal Tax Authority (FTA). Non-compliance carries significant FTA penalties. Saif Chartered Accountants provides TP studies, arm's length benchmarking, TP documentation, and CT disclosure support for UAE businesses.

Written by the Saif Chartered Accountants team · Reviewed by T. K. Chandy, Chartered Accountant · Last updated: 28 July 2026

Transfer Pricing Services Dubai — Saif Chartered Accountants UAE Tax Consultants
Tax Advisory — UAE Corporate Tax

Transfer Pricing Services in Dubai & UAE

Saif Chartered Accountants provides expert transfer pricing services in Dubai and across the UAE — helping businesses comply with the arm's length principle under UAE Corporate Tax Law (Federal Decree-Law No. 47 of 2022) and the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. As FTA-registered Tax Agents (TAN 30004113), we represent clients before the Federal Tax Authority on all transfer pricing matters.

The UAE introduced mandatory transfer pricing documentation requirements under Ministerial Decision No. 97 of 2023, requiring eligible businesses to prepare a Master File and Local File. Every taxable person with related party transactions must also submit a Disclosure Form with their corporate tax return. Non-compliance exposes businesses to FTA tax adjustments, administrative penalties, and audit risk under the 9% UAE corporate tax regime.

Our team has deep experience in transfer pricing consulting in Dubai — covering intercompany loan structuring, management fee arrangements, IP licensing, cost contribution agreements, and full OECD-compliant documentation. We deliver contemporaneous TP documentation that withstands FTA scrutiny, backed by 30+ years of UAE tax advisory practice and access to leading benchmarking databases.

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Our Transfer Pricing Services in UAE

End-to-end transfer pricing advisory — from documentation and benchmarking to FTA audit defence and APA applications.

TP Documentation — Master File & Local File

We prepare Master File and Local File documentation meeting UAE FTA requirements under Ministerial Decision No. 97 of 2023. The Master File covers your group's global business, ownership structure, supply chain, intangible property, and group-wide TP policies. The Local File provides entity-level transaction detail — functional analysis, benchmarking results, method selection rationale, and arm's length justification for each intercompany transaction. All documentation is prepared contemporaneously and retained for a minimum of 7 years.

Benchmarking & Comparability Analysis

Our transfer pricing consultants use leading commercial databases — Bureau van Dijk Orbis and TP Catalyst by Moody's — to identify comparable uncontrolled transactions and independent companies. We conduct functional and risk analysis of each related party, select the most appropriate OECD TP method, and compute the arm's length range (interquartile range) for each transaction. Accepted methods include CUP, RPM, Cost Plus, TNMM, and Profit Split, with documented rationale for method selection in line with OECD Chapter II guidance. See our dedicated transfer pricing benchmarking study service →

Transfer Pricing Policy Design

For groups entering the UAE market or restructuring existing intercompany arrangements, we design TP policies that establish arm's length pricing for intercompany services, financing, IP royalties, and cost allocations from the outset. A robust TP policy reduces annual documentation burden, provides a consistent pricing framework across jurisdictions, and aligns with BEPS Action Plan requirements. We ensure UAE TP policies are coordinated with the group's global transfer pricing framework and any applicable country-specific requirements.

Related Party Transaction Review

We review all related party and connected person transactions for arm's length compliance — including intercompany loans, management fees, IP royalties, shared services, intra-group supply chain transactions, and cost contribution arrangements. Our review identifies pricing gaps, excess charges, and thin capitalisation issues before they are flagged in an FTA audit. We advise on restructuring non-arm's length arrangements and preparing required intercompany agreements and contractual documentation to support the TP position.

Advance Pricing Agreement (APA) Support

An Advance Pricing Agreement (APA) provides prospective certainty on the transfer pricing methodology for specific related party transactions, agreed in advance with the FTA. APAs eliminate the risk of future adjustments and penalties for the covered transactions and reduce compliance uncertainty for material intercompany arrangements. We assist clients in assessing APA eligibility, preparing pre-filing submissions, drafting the formal APA application, and presenting the economic analysis to the FTA. APAs are particularly valuable for high-value intercompany financing, IP licensing, and recurring service arrangements.

FTA Transfer Pricing Audit Defence

As FTA-registered Tax Agents (TAN 30004113), we represent clients during FTA transfer pricing audits — responding to information requests, defending TP positions, and negotiating adjustments. We prepare technical position papers, analyse FTA queries, and present robust economic and legal arguments to support your arm's length pricing. Early engagement during an FTA audit significantly improves outcomes. We also assist with corporate tax reconsideration applications and Tax Dispute Resolution Committee (TDRC) proceedings where TP adjustments are disputed.

Our Transfer Pricing Process

A structured 5-step approach to OECD-compliant transfer pricing documentation for UAE corporate tax.

Transfer Pricing Life Cycle — TP Structuring, Documentation, Policy, Implementation and Compliance UAE

A robust transfer pricing framework is not a one-off exercise — it is a continuous life cycle that evolves with your business, group structure, and regulatory environment. Saif Chartered Accountants manages all five phases of the transfer pricing life cycle for UAE businesses:

  • TP Structuring & Benchmarking — Functional analysis, method selection, and arm's length range computation using commercial databases
  • TP Policy Setting — Designing intercompany pricing policies for services, financing, IP, and cost allocations aligned with OECD standards
  • TP Implementation & Monitoring — Executing intercompany agreements, monitoring actual pricing against policy, and adjusting for year-end true-ups
  • TP Documentation & Compliance — Preparing Master File, Local File, and Disclosure Form for UAE corporate tax return filing
  • TP Adjustments for Policy & ALP — Correcting non-arm's length outcomes, responding to FTA queries, and filing APA applications
1

Transaction Identification & Scoping

We map all intercompany transactions across goods, services, financing, IP, and cost allocations. We identify all related parties and connected persons under UAE CT Law definitions and determine which transactions require Local File documentation based on the materiality thresholds in Ministerial Decision No. 97 of 2023. Early scoping prevents over-documentation while ensuring all material related party transactions are covered and the Disclosure Form is complete.

2

Functional & Risk Analysis

We conduct a detailed functional analysis (FAR) of each party to the related party transaction — documenting the functions performed (manufacturing, distribution, R&D, management), assets used (tangible and intangible), and risks assumed (market risk, credit risk, inventory risk). Where intangibles are involved, we apply the OECD DEMPE framework (Development, Enhancement, Maintenance, Protection and Exploitation) and value-chain mapping to establish which group entity should earn the return on the intangible. The functional profile determines the appropriate OECD TP method and the expected arm's length return for each party, and forms the evidentiary foundation of the Local File.

3

Benchmarking & Arm's Length Range

Using commercial databases, we search for comparable uncontrolled transactions or companies with similar functional profiles, industry characteristics, and geographic relevance. We apply statistical analysis — typically the interquartile range — to establish the arm's length range for the transaction price or margin. If the tested party's actual result falls within the arm's length range, the transaction is at arm's length. If not, we advise on the adjustment approach and document the rationale in the Local File.

4

Master File & Local File Preparation

We draft the Master File covering the group's organisational structure, global business description, intangible property, intercompany financial activities, and financial and tax positions — aligned with OECD BEPS Action 13 Annex I. We prepare the Local File for the UAE entity with detailed transaction-by-transaction analysis, benchmarking results, method selection rationale, and arm's length conclusions — complying with UAE FTA Local File requirements per Ministerial Decision No. 97 of 2023 Annex II.

5

Disclosure Form & CT Return Filing

We complete the Related Party Transactions Disclosure Form required under UAE Corporate Tax Law, ensuring it aligns precisely with the Local File and supporting benchmarking analysis. The Disclosure Form is submitted with the corporate tax return by the filing deadline. All transfer pricing documentation — Master File, Local File, benchmarking analysis, and supporting agreements — is retained and organised for a minimum of 7 years for rapid response to FTA information requests or audit.

Who Needs Transfer Pricing Documentation in UAE?

UAE Corporate Tax Law applies transfer pricing obligations broadly — to multinational groups, free zone entities, holding companies, and any business with related party transactions.

  • Multinational enterprises (MNEs) with UAE subsidiaries or branches engaged in cross-border intercompany transactions — goods, services, IP, or financing
  • UAE holding companies providing management services, IP licences, financing, or shared services to subsidiaries in the UAE or abroad
  • Free zone companies — including QFZPs — transacting with mainland related parties or foreign group entities, where pricing affects QFZP eligibility
  • DMCC, JAFZA, ADGM, and DIFC entities with intercompany arrangements that directly or indirectly affect UAE taxable income
  • Companies with revenue above AED 200 million — mandatory Master File and Local File requirement under Ministerial Decision No. 97 of 2023
  • MNE groups with consolidated revenue above AED 3.15 billion — Country-by-Country Reporting (CbCR) obligation to UAE Ministry of Finance
  • Any taxable person with related party transactions — Disclosure Form required with every corporate tax return, regardless of turnover
  • Businesses paying connected persons — owners, directors, and their relatives — where payments or benefits exceed AED 500,000 per connected person and must be benchmarked to a market rate
  • Companies under FTA audit or receiving information requests on related party transactions and intercompany pricing

Why Choose Saif Chartered Accountants for Transfer Pricing

FTA-Registered Tax Agent (TAN 30004113)

As registered FTA Tax Agents, we represent your business directly before the Federal Tax Authority — responding to audit queries, submitting APA applications, filing reconsiderations, and engaging in TDRC proceedings on transfer pricing matters.

OECD-Aligned Methodology

Our transfer pricing work is built on the OECD Transfer Pricing Guidelines and BEPS Action 13 standards, ensuring your documentation aligns with international best practice and UAE FTA expectations.

Commercial Database Access

We use Bureau van Dijk Orbis and TP Catalyst by Moody's for benchmarking comparability analysis — the same databases used by Big 4 transfer pricing teams and tax authorities globally — producing defensible, data-driven arm's length ranges.

30+ Years UAE Tax Experience

Established in 1994, Saif Chartered Accountants has advised UAE businesses through every major tax reform — VAT, economic substance regulations, corporate tax, and transfer pricing — with deep local regulatory knowledge and client relationships across all sectors.

End-to-End Transfer Pricing Service

From initial scoping and benchmarking through Master File and Local File preparation, Disclosure Form filing, and FTA audit defence — we manage the complete transfer pricing lifecycle, so you have one specialist team throughout the entire process.

Integrated UAE Tax Advisory

Transfer pricing intersects with corporate tax planning, QFZP assessments, and VAT compliance. Our integrated advisory ensures your transfer pricing strategy is consistent with your overall UAE tax position.

UAE Transfer Pricing — Key Facts

9% UAE Corporate Tax Rate

UAE corporate tax applies at 9% on taxable income above AED 375,000. Transfer pricing adjustments that increase taxable income are taxed at this rate, potentially plus administrative penalties and interest for underpayment.

AED 200M — Master File & Local File

Companies with revenue exceeding AED 200 million, and MNEs with group revenue above AED 3.15 billion, must maintain a Master File and Local File. Below this threshold, the Disclosure Form is still mandatory for all related party transactions.

AED 3.15B — Country-by-Country Reporting

MNE groups with consolidated annual revenue of AED 3.15 billion or more must file a Country-by-Country Report (CbCR) with the UAE Ministry of Finance — disclosing revenue, profit, tax, employees, and assets in each jurisdiction.

7-Year Documentation Retention

Transfer pricing documentation — Master File, Local File, benchmarking analysis, and supporting agreements — must be retained for a minimum of 7 years and produced promptly on FTA request during an audit or review.

Disclosure Form — All Taxable Persons

Every UAE taxable person with related party transactions must submit a Related Party Transactions Disclosure Form with their corporate tax return — regardless of revenue size or whether the Master File and Local File thresholds are met.

OECD Guidelines — Formal Reference

The UAE FTA formally adopts the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as the interpretive framework for the arm's length principle under UAE Corporate Tax Law, including BEPS-aligned documentation standards.

Frequently Asked Questions — Transfer Pricing UAE

Is transfer pricing mandatory for UAE companies under corporate tax?

Yes. Under UAE Corporate Tax Law (Federal Decree-Law No. 47 of 2022) and Ministerial Decision No. 97 of 2023, companies with related party transactions must apply the arm's length principle. Companies with revenue above AED 200 million, or that are part of an MNE group with consolidated revenue above AED 3.15 billion, must prepare Master File and Local File documentation. All taxable persons with related party transactions must file a Disclosure Form with their corporate tax return, regardless of revenue size.

What is the arm's length principle in UAE transfer pricing?

The arm's length principle requires that transactions between related parties — such as intercompany loans, management fees, IP licences, or goods traded between group entities — be priced as if they were conducted between independent parties under comparable conditions. The UAE follows the OECD Transfer Pricing Guidelines as the primary interpretive framework for applying this principle under UAE Corporate Tax Law.

What transfer pricing methods are accepted by the UAE FTA?

The FTA accepts all five OECD-approved TP methods: Comparable Uncontrolled Price (CUP), Resale Price Method (RPM), Cost Plus Method (CPM), Transactional Net Margin Method (TNMM), and Profit Split Method (PSM). The most appropriate method is selected based on the transaction type, functional profile of the parties, and the availability of reliable comparable data — with documented rationale for the selection included in the Local File.

Do free zone companies in the UAE need transfer pricing documentation?

Yes. Free zone companies subject to UAE Corporate Tax — including Qualifying Free Zone Persons (QFZPs) — must comply with transfer pricing rules. Transactions between a free zone entity and its mainland related parties are particularly scrutinised, as non-arm's length pricing can disqualify QFZP status and expose all income to the 9% corporate tax rate. We advise on structuring intercompany arrangements to protect QFZP eligibility.

What are the penalties for transfer pricing non-compliance in UAE?

The UAE FTA has broad powers to adjust transactions that do not meet the arm's length standard, resulting in additional corporate tax, interest, and administrative penalties. Failure to maintain TP documentation, failure to submit the Disclosure Form, or maintaining non-arm's length pricing all constitute compliance failures. Contemporaneous, FTA-ready documentation is the strongest defence against adjustments and penalties.

What is a Country-by-Country Report (CbCR) in UAE?

MNE groups with consolidated annual revenue of AED 3.15 billion or more must file a Country-by-Country Report (CbCR) with the UAE Ministry of Finance. The CbCR discloses, for each jurisdiction in which the group operates: revenue (related and unrelated), profit before tax, income tax paid and accrued, number of employees, and tangible assets. The report enables tax authorities globally to assess whether profits are being shifted away from high-tax jurisdictions.

What are the UAE transfer pricing disclosure form thresholds?

Disclosure of related party transactions is required in the corporate tax return where the aggregate value of all related party transactions exceeds AED 40 million in the tax period. Once that aggregate is exceeded, each category — goods, services, intellectual property, interest, assets, liabilities, and others — is disclosed separately where the category value exceeds AED 4 million. Payments or benefits to a connected person (with their related parties) must be disclosed where they exceed AED 500,000 per connected person. Balance-sheet items such as intercompany loan balances count toward the AED 40 million aggregate — not only profit-and-loss transactions. These disclosure thresholds are separate from, and much lower than, the AED 200 million revenue threshold that triggers the Master File and Local File.

What is the difference between related parties and connected persons in UAE transfer pricing?

Related parties are entities or individuals linked by ownership or control (broadly 50% or more) — such as a parent, subsidiary, or sister company. Connected persons are the owners of the business, its directors or officers, and their relatives, plus any entity they control. Both are subject to the arm's length principle: payments to connected persons (for example director remuneration or shareholder services) must be at market value and are deductible for corporate tax only to the extent they correspond to the market rate for the work actually performed.

Need Transfer Pricing Services in Dubai?

Contact Saif Chartered Accountants for expert transfer pricing documentation, benchmarking, policy design, or FTA audit defence. As FTA-registered Tax Agents (TAN 30004113), we handle the full transfer pricing lifecycle for UAE businesses.

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Benchmarking Guide

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UAE Regulatory References

Our services are governed by and aligned with UAE legislation and international professional standards.

  • Federal Tax Authority (FTA) — FTA portal for UAE Corporate Tax and transfer pricing disclosure requirements under Ministerial Decision No. 97 of 2023.
  • UAE Corporate Tax — u.ae — UAE government guidance on Corporate Tax related-party transaction rules and disclosure obligations.
  • OECD Transfer Pricing Guidelines — OECD arm's length principles adopted by the UAE for related-party pricing under UAE CT law.
  • IFRS Foundation — International Financial Reporting Standards required for UAE company accounts used in transfer pricing analysis.

What Our Clients Say

Transfer pricing specialists serving UAE businesses and multinational groups since 1994.

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