UAE Transfer Pricing Compliance Services (Dubai)

Expert guidance on TP documentation, analysis, and compliance with OECD and UAE regulations for your business in Dubai and across the Emirates

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Navigating Transfer Pricing Complexities in the UAE: How We Help

With the UAE's Corporate Tax implementation, businesses face significant transfer pricing compliance challenges. Non-compliance risks include substantial penalties, Federal Tax Authority audits, and potential international tax disputes.

At Inlex Partners, our Dubai-based transfer pricing specialists provide comprehensive solutions tailored to UAE regulations. We ensure your business remains fully compliant with Federal Tax Authority requirements while optimizing your cross-border transactions within the framework of UAE law and OECD guidelines.

Our team brings extensive experience in UAE transfer pricing documentation, related party transaction analysis, and defending positions during tax authority inquiries across Dubai, Abu Dhabi, and all Emirates.

Understanding Transfer Pricing (TP) Essentials for UAE Businesses

Transfer pricing refers to the rules and methods for pricing transactions between related entities, such as subsidiaries or branches of the same corporate group. Under UAE Corporate Tax legislation, these transactions must be conducted at "arm's length" prices - meaning prices that would be charged between independent entities in comparable circumstances.

Key Transfer Pricing Concepts in the UAE

  • Arm's Length Principle: The cornerstone of UAE transfer pricing regulations, requiring related party transactions to be priced as if conducted between independent parties
  • Related Parties: Entities connected through management, control, or capital ownership as defined under UAE Corporate Tax legislation
  • Documentation Requirements: Master File, Local File, and Country-by-Country Reporting obligations for qualifying businesses in the UAE
  • OECD Alignment: UAE transfer pricing regulations follow OECD Transfer Pricing Guidelines while incorporating specific local requirements

With the Federal Tax Authority's increasing focus on transfer pricing compliance, UAE businesses must establish robust documentation and defensible pricing policies. Inlex Partners provides expert guidance to navigate these complex requirements while supporting your business objectives.

Comprehensive Transfer Pricing Services in Dubai & the UAE

Expert transfer pricing solutions ensuring compliance with Federal Tax Authority requirements and OECD guidelines

Transfer Pricing Documentation

Expert preparation of Master File, Local File, and Country-by-Country Reports (CbCR) that fully comply with UAE Federal Tax Authority requirements and OECD guidelines.

Related Party Transaction Analysis

Comprehensive analysis of intra-group transactions ensuring arm's length pricing principles and compliance with UAE Corporate Tax and transfer pricing regulations.

Benchmarking Studies

Detailed comparative analysis using UAE and global databases to establish appropriate arm's length ranges for your related party transactions.

Global TP Strategy Development

Creation of robust transfer pricing policies aligned with UAE Corporate Tax requirements and your global business objectives.

Risk Assessment & Audit Support

Proactive identification of transfer pricing risks and expert representation during UAE Federal Tax Authority audits and inquiries.

Cross-Border Transaction Planning

Strategic planning for international related party transactions to optimize tax efficiency while maintaining compliance with UAE regulations.

Which Businesses Require TP Compliance in the UAE?

Transfer pricing regulations impact a wide range of businesses operating in the UAE

Multinational Enterprises (MNEs)

Large groups with global presence including UAE operations that meet Country-by-Country Reporting thresholds (AED 3.15 billion consolidated revenue).

UAE Corporate Tax Entities

Companies subject to UAE Corporate Tax with related party transactions, regardless of size, must maintain appropriate transfer pricing documentation.

Free Zone & Mainland Operations

Businesses with operations in both UAE Free Zones and Mainland facing complex transfer pricing requirements under the Corporate Tax regime.

International Groups with UAE Subsidiaries

Foreign groups with UAE subsidiaries or permanent establishments that conduct cross-border related party transactions.

How We Ensure Your Business Meets TP Compliance Requirements

Our systematic approach to UAE transfer pricing compliance ensures comprehensive documentation and defensible positions

1. Initial Consultation & Assessment

We evaluate your UAE entity structure, related party transactions, and documentation requirements under UAE Corporate Tax and transfer pricing regulations.

2. Functional Analysis

Thorough examination of functions performed, assets employed, and risks assumed by each entity in your UAE-based group and international operations.

3. Benchmarking & Method Selection

Selection of appropriate transfer pricing methods and comparable data from UAE and global databases to establish arm's length price ranges.

4. Documentation Preparation

Expert preparation of Master File, Local File, and Country-by-Country Reports as required by UAE Federal Tax Authority and OECD guidelines.

5. Implementation & Compliance

Assistance with implementing robust transfer pricing policies across your UAE operations and ensuring ongoing compliance with documentation requirements.

6. Continuous Support & Defense

Ongoing guidance with UAE Corporate Tax updates, annual documentation reviews, and expert support during Federal Tax Authority inquiries or audits.

Answering Common Questions About Transfer Pricing in the UAE

What are the UAE transfer pricing documentation requirements?
UAE transfer pricing regulations require qualifying businesses to prepare and maintain transfer pricing documentation including master file, local file, and potentially country-by-country reporting. The documentation must demonstrate compliance with the arm's length principle and OECD guidelines for related party transactions. Under UAE Corporate Tax law, businesses must have this documentation available upon request from the Federal Tax Authority.
When should UAE businesses prepare transfer pricing documentation?
UAE businesses should prepare transfer pricing documentation before filing their corporate tax returns. The documentation should be contemporaneous and regularly updated to reflect any changes in related party transactions or business structures. It's crucial to maintain up-to-date documentation to ensure compliance with Federal Tax Authority requirements and avoid penalties under UAE Corporate Tax law.
What transactions are subject to transfer pricing rules in the UAE?
Transfer pricing rules in the UAE apply to all related party transactions, including but not limited to: sale or purchase of goods, provision of services, sharing of intangible assets, financial transactions, and cost sharing arrangements. These transactions must be conducted at arm's length prices and properly documented. This includes transactions between UAE entities and those between UAE and foreign related parties.
How does the arm's length principle apply to UAE transfer pricing?
The arm's length principle requires that related party transactions be priced as if they were conducted between independent parties. UAE businesses must conduct comparability analysis, choose appropriate transfer pricing methods, and maintain documentation to demonstrate compliance with this principle in accordance with OECD guidelines and UAE Corporate Tax legislation.
What are the penalties for transfer pricing non-compliance in the UAE?
Under UAE Corporate Tax law, non-compliance with transfer pricing regulations can result in significant penalties, including fines for missing or incomplete documentation, adjustment of taxable income, additional tax assessments, and potential interest on underpaid taxes. The Federal Tax Authority may also conduct detailed audits and request extensive information from non-compliant businesses.
Do UAE Free Zone entities need to comply with transfer pricing rules?
Yes, UAE Free Zone entities are subject to transfer pricing rules under the UAE Corporate Tax regime. While qualifying Free Zone entities may benefit from preferential tax rates, they must still comply with transfer pricing requirements for transactions with related parties, particularly when dealing with mainland UAE entities or foreign related parties. Proper documentation is essential for Free Zone businesses to maintain their preferential tax status.

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