Transfer Pricing Services

Businesses operating in the United Arab Emirates may enter into transactions with related parties, group companies, shareholders or connected persons. These transactions can have Corporate Tax implications and may require businesses to demonstrate that pricing and transaction terms comply with the applicable UAE transfer pricing rules.

Gupta Accountants provides Transfer Pricing Services in the UAE to help businesses review related-party transactions, assess arm’s-length pricing, evaluate documentation requirements and address relevant Corporate Tax disclosure obligations.

Our services are designed for UAE mainland companies, free zone entities, small and medium-sized businesses, and multinational groups that need practical assistance assessing their transfer pricing position and maintaining appropriate supporting records.

What Is Transfer Pricing Under UAE Corporate Tax?

Transfer pricing refers to the pricing and terms applied to transactions between related parties. These transactions may include the sale of goods, provision of services, loans, management fees, royalties, asset transfers and other commercial arrangements.

Under the UAE Corporate Tax framework, transactions with related parties must generally satisfy the arm’s-length principle. This means that the conditions of the transaction should be consistent with those that would have been agreed between independent parties in comparable circumstances.

The UAE rules also address transactions with connected persons, including certain payments and benefits involving owners, directors and other relevant individuals.

Businesses should assess their transactions, identify applicable requirements and maintain suitable evidence to support their tax treatment. The documentation and disclosure obligations depend on the nature and value of the transactions, the taxpayer's circumstances and the applicable rules.

Our Transfer Pricing Services in the UAE

1. Related-Party Transaction Review

We help businesses identify and review transactions that may fall within the UAE transfer pricing framework.

Our review may cover:

• Transactions between UAE group companies.

• Cross-border transactions with overseas related parties.

• Sales and purchases of goods between group entities.

• Intercompany management and administrative service fees.

• Loans, advances and other financing arrangements.

• Royalties, intellectual property arrangements and licence fees.

• Transfers of assets or business functions between related entities.

The objective is to understand the commercial substance of the transactions and identify matters requiring further transfer pricing analysis or documentation.

2. Arm’s-Length Pricing Assessment

We assist businesses in assessing whether the pricing and conditions of relevant related-party transactions are consistent with the arm’s-length principle.

Depending on the transaction, the review may consider:

• The commercial nature and purpose of the arrangement.

• The functions performed by each party.

• The assets used and risks assumed.

• The contractual terms and actual conduct of the parties.

• The availability of comparable transactions or market information.

• The suitability of an applicable transfer pricing method.

Where appropriate, the assessment may involve benchmarking or economic analysis. The methodology depends on the transaction and the availability and reliability of relevant information.

3. Transfer Pricing Documentation Support

Businesses may need to maintain supporting documentation to demonstrate how their related-party transactions have been assessed.

Gupta Accountants can assist with reviewing and organising relevant information, including:

• Intercompany agreements and contracts.

• Invoices and transaction schedules.

• Descriptions of business activities and transaction flows.

• Functional, asset and risk analysis.

• Pricing calculations and supporting evidence.

• Relevant group information and financial records.

We also help assess whether additional documentation may be required under the applicable UAE transfer pricing rules.

4. Local File and Master File Requirements

Certain UAE businesses may be required to maintain a Local File, a Master File or both, depending on the applicable conditions and thresholds.

A Local File generally provides detailed information about relevant local entities and their material related-party transactions. A Master File provides a broader overview of the multinational group's global business operations, organisational structure and transfer pricing arrangements.

Our services can include assessing whether these documentation requirements apply, identifying the information needed and assisting with the preparation or review of relevant documentation.

Not every UAE business is required to prepare both files. The applicable requirements should be assessed using the relevant legislation, decisions and guidance.

5. Transfer Pricing Disclosure Review

Corporate Tax returns may require disclosure of relevant related-party transactions and connected-person arrangements where the applicable requirements are met.

We help businesses review transaction information, reconcile relevant figures with available accounting records and identify disclosure matters that require attention.

Our review may include:

• Identifying potentially reportable transactions.

• Reviewing related-party and connected-person classifications.

• Checking transaction amounts against relevant disclosure thresholds.

• Comparing disclosure information with financial records.

• Identifying inconsistencies requiring clarification before filing.

This service can support the preparation of accurate Corporate Tax disclosures but does not replace a complete review of all Corporate Tax return obligations.

6. Intercompany Agreements and Management Fees

Intercompany service fees and management charges can require careful review where related entities provide shared services or allocate group expenses.

We assist businesses in reviewing the commercial basis of these arrangements and the supporting information available.

The review may consider:

• The services actually provided.

• The parties receiving the benefits.

• The basis used to calculate the charges.

• The allocation of shared expenses.

• The contractual terms and supporting invoices.

• The consistency between the arrangement and the recorded accounting treatment.

The purpose is to help businesses establish an appropriate evidence trail and identify whether the pricing or documentation needs further assessment.

7. Intercompany Loans and Financing Transactions

Loans and other financial arrangements between related parties may require transfer pricing consideration.

Our review may cover the principal amount, interest rate, repayment terms, duration, guarantees and other relevant features of the arrangement.

Where appropriate, we help assess the information required to support the pricing and commercial terms of intercompany financing, taking account of the parties' circumstances and relevant market evidence.

8. Connected-Person Payments Review

Certain payments or benefits provided to owners, directors and other connected persons may require assessment under UAE Corporate Tax rules.

We help businesses review relevant remuneration, service fees and other payments to identify whether the arrangements and amounts require additional support or documentation.

The assessment considers the nature of the payment, the relationship between the parties and the applicable conditions under the UAE Corporate Tax framework.

9. Transfer Pricing Compliance for Free Zone Companies

Free zone companies should consider transfer pricing requirements separately from their eligibility for the Corporate Tax treatment available to qualifying Free Zone Persons.

Where applicable, related-party transactions must be assessed under the UAE transfer pricing framework even if a company benefits from a preferential Corporate Tax rate on qualifying income.

Our services can help free zone businesses review intercompany transactions, relevant documentation, disclosure requirements and the consistency of their transfer pricing arrangements with their wider tax position.

10. Transfer Pricing Risk Assessment

We help businesses identify areas where their existing transfer pricing arrangements may require further review.

A risk assessment may consider:

• Significant related-party transactions without written agreements.

• Pricing methods that lack clear supporting evidence.

• Management charges without adequate service descriptions.

• Intercompany loans with unclear pricing terms.

• Differences between accounting records and tax disclosures.

• Incomplete transaction documentation.

• Changes in the group's business structure or operating model.

The review helps prioritise areas requiring further analysis and supports the development of an appropriate documentation and compliance plan.

Which Businesses May Need Transfer Pricing Services?

Transfer pricing support may be relevant to:

• UAE companies conducting transactions with overseas group entities.

• Businesses with multiple related companies in the UAE.

• Companies paying management fees or shared service charges.

• Businesses receiving or providing intercompany loans.

• Free zone entities transacting with related parties.

• Multinational groups operating through UAE subsidiaries or branches.

• Companies with significant shareholder or connected-person transactions.

• Businesses preparing transfer pricing documentation or reviewing Corporate Tax disclosures.

The precise obligations vary according to the transaction, the parties involved and the applicable requirements. A business should assess its circumstances rather than assume that every related-party transaction triggers the same documentation or disclosure obligations.

Our Transfer Pricing Review Process

Step 1: Understand the Business and Group Structure

We review the company's activities, ownership structure and relevant relationships to identify transactions that may require transfer pricing consideration.

Step 2: Identify Relevant Transactions

We help compile the relevant transaction categories, counterparties, values and supporting accounting information.

Step 3: Review Pricing and Commercial Arrangements

We examine the available contracts, transaction terms and supporting evidence to identify areas requiring further analysis.

Step 4: Assess Applicable Compliance Requirements

We consider the relevant arm’s-length, disclosure and documentation requirements, including whether Local File or Master File obligations may apply.

Step 5: Identify Documentation Gaps

We highlight missing records, inconsistent information or other matters that may need to be addressed.

Step 6: Support Documentation and Compliance

Depending on the agreed scope, we assist with preparing or reviewing relevant documentation, organising supporting information and addressing applicable Corporate Tax compliance requirements.

Why Choose Gupta Accountants for Transfer Pricing Services?

UAE Corporate Tax focus: Our approach considers transfer pricing within the wider UAE Corporate Tax framework.

Transaction-specific review: We assess the actual arrangements and commercial circumstances rather than applying the same approach to every transaction.

Documentation support: We help businesses organise relevant contracts, transaction information and supporting records.

Practical compliance assistance: We focus on identifying applicable requirements and areas needing further attention.

Support for different business structures: Our services can be tailored to mainland companies, free zone entities and businesses operating within international groups.

Frequently Asked Questions - UAE Transfer Pricing

Is transfer pricing applicable to UAE businesses?

The UAE Corporate Tax framework contains transfer pricing rules for transactions and arrangements between related parties and connected persons. The specific requirements depend on the nature of the transaction and the applicable provisions.

What is the arm’s-length principle?

The arm’s-length principle generally requires related-party transactions to be priced and structured consistently with conditions that would have been agreed between independent parties in comparable circumstances.

Does every UAE company need a transfer pricing report?

No. Transfer pricing requirements vary by business and transaction. While the arm’s-length principle may apply to relevant transactions, formal documentation obligations depend on the applicable conditions and thresholds.

What are a Local File and a Master File?

A Local File provides detailed information about relevant local entities and their material related-party transactions. A Master File provides an overview of the multinational group's global business and transfer pricing arrangements. Eligibility and documentation requirements should be assessed under the applicable UAE rules.

Are transfer pricing rules applicable to free zone companies?

Relevant free zone businesses are subject to UAE transfer pricing requirements. A company's qualifying Free Zone Person status does not, by itself, remove the need to assess related-party transactions under the applicable rules.

Do intercompany management fees need transfer pricing support?

They may require review to establish the nature of the services, the commercial basis for the charge and whether the pricing and supporting records are appropriate under the applicable rules.

What is the difference between transfer pricing and connected-person payments?

Transfer pricing generally concerns transactions between related parties. Connected-person rules address certain payments or benefits involving individuals or entities connected to a taxable person. The relevant provisions and conditions should be assessed separately where necessary.

Can Gupta Accountants help with transfer pricing documentation?

Gupta Accountants can assist with reviewing related-party transactions, assessing documentation requirements and supporting the preparation or review of relevant records, subject to the agreed scope of work.

Request Transfer Pricing Services in the UAE

If your business has related-party transactions, intercompany financing, management charges or transfer pricing documentation requirements, Gupta Accountants can help you assess the relevant obligations and organise appropriate supporting records.

Contact us to discuss your business structure and transfer pricing requirements.

सर्वे भवन्तु सुखिनः । सर्वे सन्तु निरामयाः ।
सर्वे भद्राणि पश्यन्तु । मा कश्चिद्दुःखभाग्भवेत् ।