The UAE Corporate Tax Law and Ministerial Decision No. 97 of 2023 require transactions between related parties and connected persons to be priced at arm’s length, with contemporaneous documentation to support that position.
For multinational groups with UAE entities, this creates compliance obligations that need to be addressed proactively, before the FTA begins asking questions.
Policy and Pricing
Transfer Pricing Policy Framework
Group policies that reflect actual functions, assets and risks and satisfy both OECD guidelines and UAE requirements: pricing of goods, management services, royalties, intra-group financing and shared costs, with safe harbour eligibility assessed and documented.
Functional, Asset and Risk Analysis
A clear FAR analysis mapping which entities perform significant functions, bear economic risk and hold key assets, translated into a pricing position that reflects actual substance and forms the foundation for documentation and dispute response.
Documentation
Local File, Master File and Harmonised Group Documentation
Preparation and review of Master and Local Files where thresholds are met, ensuring consistency between the group narrative and entity-level positions: working alongside local advisors to avoid contradictions across the group’s TP positions.
Country-by-Country Reporting
CbCR preparation and submission for qualifying groups, including notification obligations and consistency checks against the Master File and Local Files.
Benchmarking Studies
Benchmarking analyses across goods, services, royalties, financing and management fees, with comparable sets built on commercial logic and economic substance rather than mechanical database filters, to a standard that supports regulatory scrutiny.
Compliance and Disclosures
Related Party Disclosures in the CT Return
Identifying relevant related-party and connected-person relationships, confirming transactions requiring disclosure, and preparing the supporting schedules aligned to the transfer pricing documentation for consistency.
Value Chain Analysis and Operating Model Restructuring
Evaluating the TP implications of reorganisations, supply chain changes or function shifts between entities, advising on exit charges where applicable and documenting the before and after position.
Dispute Prevention and Certainty
APAs, MAP and Dispute Support
Advising on the viability of unilateral and bilateral Advance Pricing Agreements with the FTA, coordinating Mutual Agreement Procedure filings where double taxation arises, and representing groups before the Tax Disputes Resolution Committee with economic counter-analysis.
How We Work
Partner-led, with a dedicated team covering the UAE, GCC and 20-plus jurisdictions globally. We have access to international databases covering financials, services and IP agreements, and work alongside local advisors where multi-jurisdiction documentation coordination is required.