UAE transfer pricing services
Scope-first support for related-party pricing, documentation and Corporate Tax disclosures. We start with a scoping call and a written list of what is in and out of scope. A study is quoted from AED 5,000 with explicit exclusions — not as a fixed price for every multinational.
Arm's length applies more broadly than the documentation thresholds
Any UAE taxable person with related-party or connected-person transactions must price them at arm's length. The mandatory master/local file thresholds under Ministerial Decision 97 of 2023 — taxpayer revenue of at least AED 200 million, or MNE consolidated revenue of at least AED 3.15 billion — trigger formal documentation, but they do not remove the arm's-length principle for smaller businesses. A small company with an owner-related transaction still needs to be able to defend the pricing.
What a TP engagement can cover
Scoping and risk review
Identify related-party relationships, list transactions in the period, rank by materiality and flag areas where pricing is likely to be challenged.
Functional analysis
Describe the functions, assets and risks each party brings to the transaction. This is the basis for picking an appropriate pricing method.
Benchmarking
Where relevant, a database search for comparable independent transactions, with search criteria documented and results explained.
Master / local file
Where the thresholds are met, prepare master and local file documents to the structure required by the Ministerial Decision.
CT return disclosures
Support the related-party disclosure sections of the Corporate Tax return and document positions taken.
Specialist escalation
Complex multinational restructurings, intangibles valuation and APA/MAP work are escalated to a specialist partner rather than attempted in-house.
Thresholds and documentation at a glance
| Who | Master file | Local file | Disclosure & arm's-length |
|---|---|---|---|
| Taxpayer revenue < AED 200m and MNE < AED 3.15bn | Not mandatory | Not mandatory | Yes |
| Taxpayer revenue ≥ AED 200m | May be required | Yes | Yes |
| Constituent entity of MNE group with consolidated revenue ≥ AED 3.15bn | Yes | Yes | Yes |
Simplified summary. Specific conditions and exemptions apply; always read the current decision for your facts.
Frequently asked questions
Do small companies need to think about transfer pricing?
If related-party transactions exist, yes. The master/local file thresholds exempt smaller taxpayers from formal documentation but not from the arm's-length principle. Owner salaries, group recharges and loans between connected entities are common areas to review.
Are domestic UAE related-party transactions in scope?
Yes. Transfer pricing rules apply to related-party transactions whether the counterparty is in the UAE or abroad, subject to the specific conditions in the Corporate Tax law and Ministerial Decision 97 of 2023.
When are master/local files required?
Under Ministerial Decision 97 of 2023, a local file is required where taxpayer revenue is at least AED 200 million in the relevant period. A master file is required where the taxpayer is a constituent entity of a multinational group with consolidated revenue of at least AED 3.15 billion.
What does a TP study include?
Scope varies. A typical study includes functional analysis of the transaction, selection of a transfer-pricing method, benchmarking (database or internal comparables), conclusion on arm's-length range and recommendation. Complex transactions — intangibles, business restructuring, financial transactions — are scoped separately.
Request a TP scoping call
Share your related-party transactions and revenue level. We send a written scope with exclusions and fee before any study begins.
Start scoping