Transfer pricing compliance isn’t optional under UAE corporate tax. It is a condition of Qualifying Free Zone Person status, and a documented requirement for related-party transactions. FinApt Group helps you benchmark, document and defend your related-party pricing.
Benchmarking and Economic Analysis
We benchmark your related-party transactions against comparable arm’s-length data. That covers intercompany loans, management fees, owner remuneration and goods or service pricing between group entities.
FinApt experience: benchmarking delivered for owner remuneration, intercompany loans, JAFZA-based goods trading, and DMCC IT management service fees.
Transfer Pricing Compliance and Documentation
Preparation of the documentation the FTA expects to see, sized to your group’s scale.
- Master File preparation
- Local File preparation
- Country-by-Country Reporting (CbCR), for groups that meet the threshold
- Transfer Pricing Disclosure Form preparation as part of your corporate tax return filing
Transfer Pricing Policy and Advisory
Setting a defensible, workable pricing policy for intercompany transactions before disputes arise. This covers financing arrangements, service charges and goods pricing between related entities.
Related Party and Connected Person Reviews
A review of your related-party and connected-person transactions to confirm they are correctly identified, priced and disclosed. This includes reviews of connected-person payments made to owners, directors or related entities.
FinApt experience: connected-person transaction reviews as part of broader transfer pricing engagements.
Transfer Pricing Health Checks and Risk Assessment
A structured review of your existing transfer pricing position: documentation, policies and pricing outcomes. To flag gaps before an FTA review does.
Why This Matters for Corporate Tax
Transfer pricing compliance is one of the conditions a Qualifying Free Zone Person must meet to keep the 0% rate on qualifying income. It also connects to your wider corporate tax position and, for larger groups, to Pillar Two reporting. See our corporate tax services and international tax advisory.
Why FinApt Group for Transfer Pricing
- Transfer pricing specialists work alongside the corporate tax and audit teams. Documentation and eligibility assessments are handled together, not separately.
- Benchmarking experience across free zone and mainland structures
- Senior-led engagements from scoping through to documentation delivery
Frequently Asked Questions
Does my business need transfer pricing documentation in the UAE?
Documentation thresholds are revenue-based. A Master File and Local File apply where the group has consolidated revenue of AED 3.15 billion or more, or the UAE entity itself has revenue of AED 200 million or more in the tax period. Country-by-Country Reporting applies at AED 3.15 billion consolidated group revenue.
What is a Local File and a Master File?
A Local File documents the related-party transactions of a specific UAE entity. A Master File provides a group-wide overview of the multinational’s business and transfer pricing policies. Both apply above set size thresholds.
Is transfer pricing compliance linked to Qualifying Free Zone Person status?
Yes. Complying with the arm’s length principle and transfer pricing documentation requirements is one of the conditions for maintaining QFZP status and the 0% rate on qualifying income.
What happens if my transfer pricing isn’t properly documented?
Undocumented or unsupported related-party pricing can be challenged by the FTA. That can mean adjustments and penalties, and can put QFZP status at risk.
Do small or single-country businesses need transfer pricing documentation?
Requirements scale with size and the nature of related-party dealings. Even smaller groups with related-party or connected-person transactions should have their pricing benchmarked and disclosed correctly.