Transfer Pricing Benchmarking
UAE Corporate Tax brought OECD-aligned transfer pricing rules for related-party and connected-person transactions — documentation is no longer optional for groups above the threshold.
Overview
Related-party transactions — management fees, intercompany financing, royalties, cost allocations — now need to be priced at arm's length and, above certain thresholds, documented through a Local File and Master File. For multinational groups, different countries' TP rules don't automatically align, so a benchmark that satisfies one authority won't necessarily satisfy the other.
What's included
- Related-party and connected-person transaction identification
- Arm's length benchmarking studies using comparable company data
- Local File and Master File preparation
- Transfer pricing disclosure form support for Corporate Tax returns
- Intercompany agreement review and drafting support
- Cross-border TP alignment for international group structures
Who this is for
UAE groups with related-party transactions above the applicable Corporate Tax thresholds, and multinational groups with an overseas holding or subsidiary structure.
Frequently asked questions
No — obligations scale with transaction value and group revenue. Smaller related-party dealings may only need disclosure, not a full benchmarking study. We size this correctly rather than over-scoping.
The definition covers more than direct shareholding — it includes connected persons such as directors, controllers and certain family relationships. We map your actual related-party universe rather than assuming it's limited to group entities.
Often the underlying comparables analysis can be leveraged, but the documentation format and thresholds differ by jurisdiction — we adapt the study for each authority rather than submitting one file twice.
Often paired with Transfer Pricing Benchmarking.
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