Evidence for related-party pricing
Documented analysis for company margins, intercompany loans, management fees, royalties and director remuneration—built around your transaction.
What the study answers
A transfer pricing benchmarking study assesses a controlled price, rate or margin against independent evidence under comparable conditions.
SAIF Chartered Accountants provides benchmarking support for businesses in Dubai and across the UAE, including mainland companies, free-zone entities and international groups. The scope starts with the actual transaction—not a preselected industry average.
A useful report explains the method, evidence and limitations so your finance team can understand the conclusion and support the pricing position. It is part of the wider transfer pricing documentation and compliance process, not a guarantee of tax authority acceptance.
What we benchmark
Agree the transaction categories, periods and deliverables before the engagement begins. Specialist data requirements are identified during scoping.
For distributors, manufacturers and service businesses, assess the tested activity and select comparable independent companies. Where TNMM is appropriate, document the profit level indicator, financial periods, screening and resulting margin range.
Output: comparable set, screening rationale and financial analysis.
Where reliable independent transactions are available, test the price directly. Review internal third-party dealings as well as external evidence, explaining differences in products, volumes, terms and market conditions before drawing a conclusion.
Output: price comparison and explanation of material differences.
Analyse the financing arrangement separately from operating margins. Review currency, tenor, repayment terms, security and borrower credit risk. Agree whether guarantee fees, cash pooling or other treasury arrangements need a separate analysis.
Output: financing assumptions, comparable rate evidence and conclusion.
Examine the service received, supporting evidence, cost pool and allocation keys before testing a charge or mark-up. Assess whether a qualifying low value-adding service approach is relevant; a generic management fee does not automatically qualify.
Output: service and cost-base analysis with pricing support.
Review the actual role, responsibilities, experience and total reward package, including salary, fees, bonus and benefits. Compare suitable remuneration evidence and assess connected-person considerations rather than using whole-company profit to justify pay.
Output: role-based remuneration comparison and documented assumptions.
Assess the licence, rights granted, territory, exclusivity and commercial responsibilities. Consider development, enhancement, maintenance, protection and exploitation of the intangible (DEMPE) alongside comparable licensing evidence where available.
Output: royalty analysis linked to the rights and functions involved.
Salary benchmarking in Dubai
For UAE Corporate tax, the useful question is not simply “What is the average salary in Dubai?” It is whether the payment for this person’s actual work is commercially supportable under the rules that apply to the business.
We can scope a remuneration comparison around duties, seniority, decision-making authority, time commitment and total reward—including salary, fees, bonus and benefits. We then explain the quality and limits of available UAE market evidence. An HR salary guide alone does not establish the tax treatment, and there is no universal FTA “salary benchmarking certificate” requirement.
Looking for pay bands for an entire workforce rather than tax support for an owner or director? That is a different HR compensation project. Looking for broader company KPI comparisons? See our financial advisory services.
Explore owner and director salary benchmarking →UAE scope and requirements
Domestic and cross-border arrangements can need attention. Apply the law and relevant reliefs to the facts of the business.
Map goods, services, financing, licences and connected-person payments. Below-threshold businesses may still need reasonable support for their pricing. Reliable internal comparables can sometimes avoid an external database search.
Free-zone status is not a blanket transfer pricing exemption.Ministerial Decision No. 97 of 2023 sets file thresholds at AED 200 million or more of Taxable Person revenue, or membership of an MNE group with at least AED 3.15 billion consolidated revenue in the relevant Tax Period.
Apply Local File scope rules and the Master File exception for UAE-only groups.The return schedule is triggered above AED 40 million of aggregate Related Party transactions; categories above AED 4 million are then reportable. Related-party dividends are excluded from these threshold calculations.
Disclosure does not replace the underlying economic analysis.Assess payments and benefits per Connected Person together with its Related Parties. This is a reporting threshold, not an automatic salary deduction or a tax-free allowance.
Evaluate market value and applicable deductibility conditions separately.Method and comparable selection
We connect the transaction’s functions, assets and risks to the selected method and evidence. The report should make it clear why a comparison is meaningful and where its limitations lie.
Read the benchmarking guide →CUP tests comparable prices; Resale Price and Cost Plus examine gross measures; TNMM tests a net profit indicator; Profit Split addresses appropriate combined-profit cases. The choice needs a reason, not a default template.
Consider internal dealings with independent parties and external company or transaction data. Agree access to relevant sources before work starts; record the actual source, date and selection criteria in the report.
Consider local, regional and other markets in the appropriate sequence. Record why the search was broadened and why candidates were accepted or rejected. Losses alone are not a sufficient reason to discard a comparable.
A net return on costs is not the same as a gross cost-plus mark-up. Explain the denominator, accounting treatment, financial periods and any comparability adjustments.
Understand the result
The interquartile range is one way to narrow a comparable set. Its usefulness depends on the quality of the method and underlying evidence.
In this simplified example, a 3.0% operating margin falls within the range. A 0.9% margin falls outside it and needs investigation. Neither the median nor the nearest boundary is an automatic adjustment target.
An in-range result does not cure an unsuitable comparable set. The FTA may examine the method, data and conclusion. The report should explain the appropriate response rather than simply label the result “passed”.
Our benchmarking process
Nine checkpoints grouped into three phases. The detailed work changes with the transaction and selected method.
Establish the facts and the pricing question.
Agree the entity, transaction category, financial period, purpose of the report and exclusions.
Understand actual conduct, contracts, assets, responsibilities and economically significant risks.
Explain the tested party, method and relevant price, rate or profit indicator.
Find independent evidence and test its reliability.
Consider internal comparables and define the external search strategy where needed.
Document geography, industry, independence and other selection criteria; record acceptance and rejection reasons.
Investigate unusual results and data gaps; justify any adjustments rather than excluding inconvenient outcomes.
Explain the result and connect it to the records.
Calculate comparable results consistently and connect the tested figures to the financial records.
Explain the range, limitations and what the result means for the transaction under review.
Provide the agreed report, explain implementation points and identify the next review triggers.
What you receive
The proposal identifies the transaction category, tested period, report format, data assumptions and agreed review points. Supporting information is provided subject to any third-party data-licensing restrictions.
A benchmarking report is not automatically a complete Local File, Master File or Corporate tax return. We can discuss those additional requirements as part of the wider engagement.
Corporate tax support →A description of the transaction, parties, period and relevant functions, assets and risks.
Reasons for the selected approach, evidence sources, search date and screening decisions.
Selected evidence, relevant financial measures, adjustments where justified and the result.
Assumptions, limitations, practical actions and reconciliation points for the finance team.
Preparing for a proposal
Start with a summary of the transaction. We will agree a secure way to exchange supporting records; do not send confidential financial data through a public form.
We quote after assessing the transaction categories, record quality, data requirements and jurisdictions involved. The proposal should distinguish the initial study, annual financial refresh, a new search and any later FTA enquiry support. Delivery timing is agreed once the scope and information gaps are understood.
Working with SAIF Chartered Accountants
Choosing a benchmarking adviser
When comparing proposals, ask who will carry out and review the analysis, which transaction categories are included, how evidence will be obtained and what happens if the data is insufficient.
Check whether the fee includes explanations to your finance team, documentation integration and follow-up questions. Request relevant experience that the adviser can substantiate. A low price, a database subscription or a “best firm” label is not a substitute for a clearly defined engagement.
Before appointing us, discuss your particular transaction and the work you need. We will clarify the scope, information requirements and any specialist support to be agreed.
Frequently asked questions
General guidance for scoping the work. Your technical position depends on the facts and applicable rules.
Ask a benchmarking specialist →It is an economic analysis comparing a controlled transaction with suitable independent evidence. The result may be a price, interest rate, remuneration comparison or profit-margin range, depending on the transaction and method.
No universal rule requires every company to buy an external database report. Assess the underlying pricing obligation, documentation requirements and reliable evidence available for the transaction. A reporting threshold is not a blanket exemption from arm’s-length pricing.
No. The benchmarking report supports the economic analysis. A Local File also covers the entity, relevant controlled transactions, functional analysis and financial information. Agree whether a Local File or Master File is included in the engagement.
Yes, the scope can include remuneration analysis. We review actual duties and the full reward package, then assess comparable roles. The connected-person rules and any applicable exceptions must be considered separately from the disclosure threshold.
No. An HR survey helps an employer set pay bands across its workforce. A Corporate tax remuneration review assesses the actual services of an owner, director or other potentially Connected Person, the full payment or benefit and relevant market evidence. A general salary guide can be one input, but it is not by itself a transaction-specific tax conclusion.
This page concerns transfer pricing and connected-person remuneration. If you want to compare working capital, profitability, reporting efficiency or other operational measures with peers, ask about a separate financial-performance advisory scope rather than a transfer pricing study.
The UAE rules do not impose a universal “salary benchmarking certificate” for every owner-manager. Where a payment to a Connected Person is subject to Article 36, the deductible amount generally must reflect the market value of the service or benefit and be incurred wholly and exclusively for the business, subject to applicable exceptions. Evidence should fit the role and facts; a formal remuneration comparison may help where the amount or risk warrants it.
No. The FTA’s CTP010 clarification explains that a job title alone does not make someone a director under Article 36. The person may still be an officer if they have the relevant strategic decision-making or binding authority. An owner may also be a Connected Person independently of their job title. Review the actual role and legal relationship before deciding what remuneration support is needed.
Not automatically. These arrangements have different pricing drivers and evidence requirements. The proposal should identify the transaction categories to be tested and explain any justified combination of closely linked transactions.
Commercial databases are possible evidence sources, but the appropriate source depends on the transaction and data coverage. We agree the required data access and scope before work begins, and identify the actual sources used in the report. No database name alone establishes the quality of a study.
Not necessarily. The search should consider local evidence, then regional and other markets as appropriate, with the reasons for broadening the search documented. A company is not a suitable comparable simply because it is in the same country.
No. The median is not an automatic UAE adjustment rule. The reliability of the range and the facts of the transaction matter. A result outside the selected range requires investigation and consideration of the appropriate treatment.
No. The simplified approach concerns qualifying low value-adding intra-group services and has conditions. It does not replace identifying the services, documenting the benefit or establishing an appropriate cost base.
Review the underlying facts and financial evidence annually. A full comparable search may be refreshed periodically where conditions are unchanged, but changes to the business, transaction or market can require an earlier update.
Fees and timing depend on transaction categories, entities, jurisdictions, evidence availability and record quality. We agree a scope-based proposal and timetable after reviewing the information. Additional files, implementation work and enquiry support should be separately identified.
No. A documented analysis supports the business’s position, but the FTA can examine the facts, method, comparable evidence and conclusion. No adviser can guarantee acceptance or the absence of an adjustment.
Practical reading
Transfer PricingUnderstand UAE transfer pricing benchmarking: documentation thresholds, comparable searches, methods and practical examples for margins, loans and director remuneration.
Read insight ↗
Corporate TaxAssess QFZP eligibility, qualifying income, excluded activities, de minimis, substance, audit and transfer pricing requirements under UAE Corporate tax.
Read insight ↗
Transfer PricingTransfer pricing Service in Dubai helps businesses comply with UAE Corporate tax rules. Learn about documentation, benchmarking, and arm’s length pricing requirements.
Read insight ↗Technical reference points
Page updated 8 October 2026. General information, not advice on a particular transaction.
Start with your transaction
Tell us what you need to price, the entities involved and the period under review. We will discuss the appropriate scope.
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