Transfer pricing Services in Dubai

No. UAE transfer pricing rules can apply to transactions with Related Parties and Connected Persons whether the counterparty is in the UAE mainland, a free zone or another country.

Taxable Persons undertaking transactions or arrangements with Related Parties or Connected Persons must consider the arm’s-length principle. Documentation and disclosure obligations depend on the facts and applicable thresholds.

Yes, if it has transactions or arrangements with Related Parties or Connected Persons, it still needs to consider arm’s-length pricing. AED 200 million is one trigger for formal Master File and Local File obligations, not an exemption from the arm’s-length principle. Check the separate disclosure thresholds and retain proportionate supporting records.

Under Ministerial Decision No. 97 of 2023, both are required where the Taxable Person’s revenue in the relevant Tax Period is at least AED 200 million, or where it is a Constituent Company of an MNE Group with total consolidated group revenue of at least AED 3.15 billion. The decision also specifies which transactions belong in the Local File.

The FTA Tax Returns Guide states that the Related Party transactions schedule is triggered when aggregate transactions with all Related Parties exceed AED 40 million. Once triggered, a transaction category is disclosed when its aggregate value exceeds AED 4 million. The Connected Persons schedule applies where the relevant aggregate exceeds AED 500,000, with reporting by Connected Person as described in the guide.

Related Parties are persons or entities linked through relationships such as ownership, control or kinship as defined by the Corporate tax Law. Connected Persons generally include an owner, director or officer of the Taxable Person, their Related Parties, and partners in an Unincorporated Partnership. The precise legal definitions and attribution rules should be applied to the facts.

A Master File gives a group-level overview of the business, organisational structure, intangibles, financing and global transfer pricing policies. A Local File focuses on the UAE entity, its material controlled transactions, functional and economic analysis, method selection and financial information. The FTA guide also describes an exception under which a UAE-headquartered group that is not an MNE Group may not need a Master File, although a Local File may still be required where the applicable threshold is met.

A study normally includes transaction delineation, functional analysis, tested-party and method selection, comparable searches, screening criteria, financial adjustments where appropriate, and calculation of an arm’s-length range or price.

A loan between Related Parties may need an arm’s-length review. The terms, currency, tenor, security, borrower creditworthiness and available comparable debt can affect the rate. The FTA Transfer pricing Guide discusses shareholder loans and intra-group lending specifically; a single standard interest rate is not appropriate for every case.

Potentially. Where the recipient is a Connected Person, the UAE Corporate tax rules generally restrict deduction to the market value of services provided and amounts incurred wholly and exclusively for the business, subject to statutory exceptions. Review the role, responsibilities, evidence and comparable remuneration before deciding whether a salary benchmark is needed.

The underlying facts and pricing results should be monitored each year. Update the policy, functional analysis or benchmark when the business model, transaction, parties, market conditions or available comparable data change materially.

The FTA Transfer pricing Guide states that a Master File and Local File may be requested within 30 days, unless the FTA agrees a longer period. A Taxable Person below the formal file thresholds should still maintain reasonable records supporting the arm’s-length nature of controlled transactions, which may also be requested within 30 days or another date directed by the FTA.

Free zone status does not remove the need to consider the arm’s-length principle. Related-party pricing can also affect the Corporate tax position and should be reviewed alongside the conditions applicable to the free zone entity.

There is no single fee or timeline for every group. Scope depends on the number and type of controlled transactions, entities, quality of financial records, availability of comparables, required deliverables and deadline. We agree the scope, data requests, milestones and fees after reviewing a short brief.

Yes. We can assess the transaction, readiness and supporting economic analysis for a unilateral APA application and assist with the process. The FTA’s APA Guide requires a pre-filing consultation before an application; that consultation does not guarantee an agreement. The final decision remains with the Federal Tax Authority.