A2, Digital Park, Dubai Silicon Oasis, Dubai, UAE
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Accounting & Tax Advisory Practice

UAE Transfer Pricing Compliance & Master/Local File Advisory

OECD-aligned transfer pricing documentation, Arm’s Length Principle benchmarking, intercompany agreements, and disclosure forms under Article 55.

Ensure complete compliance with UAE Transfer Pricing regulations. Preparation of Transfer Pricing Master Files, Local Files, Local Benchmarking Studies, and disclosure forms.

Article 55

Transfer Pricing Law

Mandatory arm’s length standard

AED 200M

Master/Local File Cap

Revenue threshold for formal dossiers

OECD

Standardized Studies

International database benchmarking

Disclosure

Annual Return Form

Mandatory related party disclosures

The UAE Transfer Pricing Regulatory Framework

Under Chapter 10 (Articles 34 to 36 and 55) of Federal Decree-Law No. 47 of 2022 and Ministerial Decision No. 97 of 2023, transactions between Related Parties and Connected Persons must satisfy the Arm’s Length Principle. Taxable persons exceeding statutory revenue thresholds must maintain a comprehensive Transfer Pricing Master File and Local File.

Functional, Asset & Risk (FAR) Analysis

Conducting comprehensive FAR profiling to characterize entity roles (e.g. toll manufacturer, limited-risk distributor).

Economic Benchmarking Studies

Searching recognized international financial databases (Orbis, TP Catalyst) to identify comparable independent margins.

Transfer Pricing Local File Preparation

Drafting detailed Local Files documenting UAE entity operations, management structure, and related party transactions.

Group Master File Alignment

Structuring global Master Files detailing worldwide organizational structure, intangibles, and financing arrangements.

Structured Execution & Statutory Roadmap

Related Party Transaction Scoping

Mapping all intercompany goods sales, management service charges, royalties, and loan agreements.

Transfer Pricing Methodology Selection

Selecting the most appropriate method (CUP, Resale Price, Cost Plus, TNMM, or Profit Split).

Database Benchmarking

Performing multi-year statistical benchmarking to establish the interquartile arm’s length range.

Dossier Delivery & Annual Filing

Finalizing Master/Local Files and preparing disclosure schedules for the annual Corporate Tax Return.

Mandatory Documentation & Prerequisites

Intercompany Transaction Register: Itemized schedule of all related party transactions with transaction values and counterparties.
Intercompany Agreements & Contracts: Signed service level agreements, loan agreements, distribution contracts, and IP licensing deeds.
Group Global Master File: Worldwide group master file if prepared by international parent company headquarters.
Audited Financial Statements: Standalone audited balance sheet and segment profit & loss reports for the UAE entity.

Mitigating Transfer Pricing Reassessment Exposure

Transfer pricing is the primary target of international tax audits. We build robust, audit-proof economic documentation that substantiates your intercompany margins before the FTA.

Direct Practice Engagement

Schedule an Advisory Review

Engage directly with certified FTA Tax Agents, MoIAT conformity specialists, and enterprise technology architects.

Book Advisory

UAE Transfer Pricing Compliance & OECD Documentation Advisory