Skip to content

International Tax

Arm’s length pricing, disclosure forms and master and local files for transactions with related parties and connected persons.

9 deliverables
4 step process
EN · AR
Dual monitors showing intercompany pricing tables and benchmark charts
International Tax

UAE Corporate Tax requires transactions with related parties and connected persons to be priced as if they were between independent businesses. That covers intercompany services, loans, shared costs and payments to owners and their relatives. We identify these transactions, test their pricing and prepare the documentation the FTA expects.

Identification of related parties and connected persons
Mapping of intercompany and owner transactions
Functional analysis of who does what, owns what and bears which risks
Selection of the most appropriate pricing method
Benchmarking against comparable independent transactions
Transfer pricing disclosure form with the Corporate Tax return
Master file and local file preparation where required
Intercompany agreements and recharge policies
Support with FTA information requests and adjustments

01

Defensible prices

Each related-party price is backed by analysis that follows OECD-aligned methods.

02

Accurate disclosures

Your return captures every transaction the FTA expects to see.

03

Fewer adjustments

Getting pricing right up front reduces the risk of the FTA re-pricing transactions.

04

Right-sized documentation

You prepare full files only where the thresholds require them.

01Why transfer pricing matters to UAE SMEs

Transfer pricing is often seen as a concern for large multinationals, but UAE rules apply to businesses of every size. A family business that pays rent to an owner, charges a sister company for shared staff, or lends money between entities is already dealing with related parties.

If these transactions are not at market value, the FTA can adjust your taxable income. For Free Zone companies, non-compliance can also cost the 0% rate.

02How we test arm’s length pricing

We begin with a functional analysis that sets out which entity performs which functions, owns which assets and bears which risks. That determines the right pricing method, such as comparable uncontrolled price, cost plus or the transactional net margin method.

We then benchmark against independent data and document the result. Where prices fall outside the acceptable range, we recommend adjustments before the return is filed.

03Documentation that fits your size

Every business must be able to show that its related-party pricing is reasonable, and many will need to file the transfer pricing disclosure form with their return. Larger businesses must also maintain a master file and local file, which must be provided within 30 days if the FTA asks.

We scale the documentation to your thresholds, so smaller businesses are not burdened with paperwork they do not need.

  1. 1

    Map relationships

    We identify related parties, connected persons and every transaction between them.

  2. 2

    Analyse functions

    We document functions, assets and risks and choose the pricing method.

  3. 3

    Benchmark

    We test prices against comparable independent data.

  4. 4

    Document and disclose

    We prepare the disclosure form, files and agreements you need.

Generally, individuals related up to the fourth degree, entities under common ownership or control of 50% or more, and permanent establishments of the same person, among others.

Ready for books you can rely on?

Book a free 30-minute consultation. We’ll review your current setup and show you exactly what we’d do.