Arm’s-length review
We test whether your dealings with related parties and connected persons are priced as they would be between independent parties — the arm’s-length principle at the heart of UAE transfer pricing.
Arm’s-length reviews of your related-party dealings, the TP Disclosure Form filed with your Corporate Tax return, and Master File and Local File documentation where the thresholds are met.
From mapping related parties to filing the disclosure with your return.
We test whether your dealings with related parties and connected persons are priced as they would be between independent parties — the arm’s-length principle at the heart of UAE transfer pricing.
We map your related parties and connected persons and identify every intra-group transaction — goods, services, financing, IP, and management charges — that falls within scope.
We prepare the Transfer Pricing Disclosure Form filed with your Corporate Tax return, triggered where related-party transactions exceed AED 40,000,000 in aggregate or connected-person transactions exceed AED 500,000.
Where a Master File and Local File are required — MNE group revenue of AED 3.15bn or more, or taxable-person revenue of AED 200m or more — we prepare both to the required standard.
We build benchmarking analyses using comparable data to support the pricing of your controlled transactions and evidence the arm’s-length result.
We assemble contemporaneous documentation that stands up to FTA review, so your transfer-pricing position is supported by evidence rather than assertion.
A structured path from related-party mapping to a filed disclosure.
We identify your related parties and connected persons and catalogue the controlled transactions between them.
We assess whether each material transaction is priced at arm’s length and flag areas of risk.
We run benchmarking studies and prepare the Master File and Local File where the thresholds are met.
We complete the TP Disclosure Form and file it alongside your Corporate Tax return where disclosure is triggered.
Transfer pricing sits directly inside your Corporate Tax return. Because we prepare both together, your disclosure ties to your filed figures, your documentation matches the pricing you actually applied, and your position is supported by benchmarking rather than assertion.
Read the UAE transfer pricing guide, pair this with Corporate Tax filing, see all Corporate Tax services, or learn the wider rules in the UAE Corporate Tax guide.
The essentials on UAE transfer pricing and how we support it.
The arm’s-length principle requires that transactions between related parties and connected persons are priced as if they had taken place between independent parties acting in their own interests. It is the foundation of UAE transfer-pricing rules under the Corporate Tax law. Where intra-group pricing departs from an arm’s-length result, taxable income may need to be adjusted. We test your pricing against this standard and document the outcome.
Related parties are broadly persons linked through ownership, control, or kinship — for example companies under common control or a parent and its subsidiaries. Connected persons include owners of the business, directors or officers, and their related parties. Transactions with both groups fall within the transfer-pricing rules, which is why we start by mapping every relationship before looking at the pricing.
A Master File and Local File are required where either threshold is met: your business is part of a multinational group with consolidated revenue of AED 3.15 billion or more, or the taxable person has revenue of AED 200 million or more in the relevant period. Where either applies, we prepare both documents to the required standard so your documentation obligations are met.
The TP Disclosure Form is submitted together with your Corporate Tax return and summarises your transactions with related parties and connected persons. Disclosure is triggered where aggregate related-party transactions exceed AED 40,000,000, or aggregate connected-person transactions exceed AED 500,000. Where a category of related-party transactions exceeds AED 4,000,000 it is itemised separately. We prepare and file the form with your return.
Transfer pricing determines how much profit is properly attributed to your UAE business on its related-party dealings, which in turn affects taxable income. If controlled transactions are not at arm’s length, the FTA can adjust your taxable income and apply Corporate Tax accordingly. Getting the pricing and documentation right protects your Corporate Tax position, which is why we handle both together.
Benchmarking compares the pricing or margins of your controlled transactions against those of independent comparable companies or transactions, using recognised databases and methods. It provides the evidence that your pricing sits within an arm’s-length range. Without it, an arm’s-length claim is an assertion rather than a supported position, so we build benchmarking studies to underpin your documentation.
Tell us about your related-party and connected-person transactions, and a UAE specialist will come back to you shortly about disclosure and documentation.