Transfer Pricing Services in Dubai
Disclosure Forms, Benchmarking, Master File, Local File and FTA Review Support
If your business has transactions with group companies, shareholders, directors, officers or family-linked entities in the UAE or outside the UAE, transfer pricing rules may apply. Credora reviews related-party and connected-person transactions, prepares benchmarking support, assists with transfer pricing disclosure forms, prepares Master File and Local File documentation where required, and supports responses to FTA information requests.
Initial transfer pricing review · Clear scope before work starts · Benchmarking aligned with UAE Corporate Tax rules
Last reviewed: July 2026 · Reviewed by Credora Consultancy LLC, led by an FTA Registered Tax Agent in Dubai · Based on UAE Corporate Tax transfer pricing provisions, Ministerial Decision No. 97 of 2023 and FTA transfer pricing guidance.
Transfer Pricing Position in the UAE
The arm’s length principle applies to transactions with related parties and connected persons, whether the transaction is domestic or cross-border.
The transfer pricing disclosure form is linked to the Corporate Tax return. Related-party disclosure may apply where aggregate related-party transactions exceed AED 40 million, with categories above AED 4 million disclosed. Connected-person disclosure may apply where payments or benefits to a connected person exceed AED 500,000.
Master File and Local File documentation may be required where standalone revenue is AED 200 million or more, or where the business is part of a multinational group with consolidated revenue of AED 3.15 billion or more.
Qualifying Free Zone Person status requires transfer pricing compliance and documentation support where applicable.
Covered dealings can include goods, services, royalties, management fees, loans, asset transfers, liabilities, shareholder payments and director or officer benefits.
Who Needs Transfer Pricing Support in the UAE?
Transfer pricing support is important for businesses that have transactions with related parties, connected persons, group companies, shareholders, directors, officers or family-linked entities. The risk is higher where the pricing affects Corporate Tax deductions, free zone qualifying income, intercompany balances or disclosure schedules.
Related-Party Transactions
Businesses with sales, purchases, services, loans, royalties, rent or management fees involving group companies or commonly controlled entities.
Owner-Managed Businesses
Companies paying salaries, bonuses, rent, consultancy fees or benefits to shareholders, directors, officers or their related parties.
Free Zone Companies
Free zone entities that need to support qualifying income, mainland transactions, intercompany charges and QFZP documentation requirements.
Multinational Groups
Groups with cross-border transactions, UAE subsidiaries, regional headquarters, intercompany financing or documentation requirements.
Who Is Covered by UAE Transfer Pricing Rules?
Transfer pricing is the pricing of controlled transactions between parties that are not independent of each other. Under the UAE Corporate Tax Law, controlled transactions must be priced on an arm’s length basis, as if the parties were independent. Incorrect pricing may result in taxable income adjustments, denied deductions, tax assessments and penalties.
| Category | Who It Includes | Typical Examples |
|---|---|---|
| Related parties | Companies and individuals linked by ownership, control, common ownership, common control or family relationship under the UAE Corporate Tax rules. | Management fees charged by a group company, intercompany loans, rent charged by a sister company, sale of goods to a parent company, or use of intellectual property owned by a related entity. |
| Connected persons | Owners, directors, officers and their related parties, where payments or benefits are made by the business. | Shareholder salary, director fee, consultancy fee paid to a director-linked company, company car benefit or other owner benefit. |
Pricing is reviewed using recognised transfer pricing methods, including comparable uncontrolled price, resale price, cost plus, transactional net margin method and profit split. The method should match the facts, functions, assets, risks and available comparable data. Credora also reviews consistency with accounting records and Corporate Tax return positions.
UAE Transfer Pricing Filing and Documentation Requirements
Transfer pricing obligations have separate triggers. A business may need to comply with the arm’s length principle even if it is not required to submit a disclosure form or maintain a Master File and Local File.
| Obligation | Trigger | Timing |
|---|---|---|
| Arm’s length pricing | Applies to controlled transactions with related parties and connected persons. | Reviewed when transactions are priced and when Corporate Tax positions are prepared. |
| Related-party disclosure schedule | Aggregate related-party transactions above AED 40 million. Categories above AED 4 million are then disclosed. | Filed with the Corporate Tax return. |
| Connected-persons disclosure schedule | Payments or benefits to a connected person above AED 500,000. | Filed with the Corporate Tax return. |
| Master File and Local File | Standalone revenue of AED 200 million or more, or membership of a multinational group with consolidated revenue of AED 3.15 billion or more. | Maintained and provided within 30 days if requested by the FTA. |
| Country-by-Country Reporting | UAE-headquartered multinational groups with consolidated revenue of AED 3.15 billion or more, subject to applicable rules. | Generally within 12 months of the group’s financial year end. |
Important Point
A threshold exemption for a form or file does not remove the arm’s length requirement. The FTA can request reasonable support for related-party and connected-person transactions. Preparing the working file before filing helps keep the Corporate Tax return, accounting records and transfer pricing position consistent.
Free Zone Compliance
Transfer Pricing for Free Zone Companies and QFZP Status
Qualifying Free Zone Person status requires compliance with the arm’s length principle and transfer pricing documentation requirements where applicable. Free zone entities should review their related-party income, mainland transactions, substance, intercompany services, financing and pricing policies before filing the Corporate Tax return.
Mainland Transactions
Pricing should support both the mainland deduction and the free zone income classification.
Separate Documentation
A qualifying free zone entity may need its own Local File and transaction analysis where documentation thresholds are met.
Substance and Pricing
The functional profile, employees, assets, risks and intercompany charges should be aligned.
Commodity Trading
Commodity traders should review price-setting, recognised pricing sources and free zone qualifying income requirements.
Our Services
Transfer Pricing Services in Dubai and Across the UAE
Credora provides transfer pricing support based on the transaction profile, documentation requirement, filing deadline and FTA review risk of the business.
TP Review and Transaction Mapping
Review of related parties, connected persons, transaction categories, account balances, payment flows and disclosure thresholds.
Benchmarking Studies
Method selection and comparable analysis for goods, services, management fees, royalties, financing, asset transfers and other controlled transactions.
TP Disclosure Form Preparation
Preparation of related-party and connected-person schedules in line with the Corporate Tax return and accounting records.
Master File and Local File
Preparation of Master File and Local File documentation under UAE Corporate Tax transfer pricing requirements.
Connected-Person Payment Reviews
Review of shareholder salaries, director fees, officer benefits, owner benefits and payments to connected-person entities.
Intercompany Agreements and TP Policy
Drafting and review of service agreements, loan terms, royalty arrangements and group transfer pricing policies.
Free Zone and QFZP TP Compliance
Transfer pricing review for qualifying income, mainland transactions, substance, documentation and free zone Corporate Tax position.
Country-by-Country Reporting
CbCR review, notification support and reporting assistance for UAE-headquartered multinational groups where applicable.
FTA Review and Adjustment Support
Support with FTA information requests, explanation letters, working papers, adjustment analysis and downward adjustment applications where required.
APA and Cross-Border Structuring Support
Support for unilateral APA matters, restructuring reviews, new entity pricing and international tax coordination.
Before Filing
Why Transfer Pricing Requires Review Before Filing
Transfer pricing is visible in the Corporate Tax return, related-party schedules, accounting records and supporting documentation. Inconsistencies between these records can lead to FTA questions, document requests or adjustments.
Reviewing transfer pricing before filing helps identify missing agreements, unsupported pricing, incorrect disclosure categories, connected-person payment issues, free zone risks and input records that may need to be corrected before submission.
Request a Transfer Pricing Review
Share your group structure, related-party transactions and filing status. Credora can review which transfer pricing obligations may apply and explain the next steps.
Credora Consultancy LLC supports UAE businesses with accounting, Corporate Tax, VAT and transfer pricing work so that accounting records, tax filings and supporting documentation remain consistent. Credora is led by an FTA Registered Tax Agent in Dubai.
How Credora Reviews Transfer Pricing Compliance
Credora follows a practical review process that connects the legal transfer pricing rules with the company’s accounting records, Corporate Tax return, financial statements and supporting documents.
1. Transaction Mapping
We identify related parties, connected persons, transaction categories, balances, payments and disclosure triggers.
2. Risk Review
We review pricing, contracts, accounting treatment, free zone position, documentation gaps and FTA review risk.
3. Benchmarking Support
Where required, we prepare method selection, comparable analysis and arm’s length support for controlled transactions.
4. Filing and Documentation
We prepare disclosure schedules, working papers, Master File, Local File or FTA response support depending on the requirement.
Trusted Transfer Pricing Consultants in Dubai
Credora Consultancy LLC is rated 5 stars on Google. Clients recommend our team for professional, responsive, and practical support with UAE tax, Corporate Tax, VAT, accounting, compliance, and business advisory services.
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Frequently Asked Questions: Transfer Pricing in the UAE
What is transfer pricing in the UAE?
Transfer pricing is the requirement that transactions with related parties and connected persons are priced at market value, as if the parties were independent. It applies under the UAE Corporate Tax rules and can affect taxable income, deductions and disclosure obligations.
Does transfer pricing apply to small businesses in Dubai?
Yes. The arm’s length principle can apply even where the business is below the disclosure or documentation thresholds. Smaller businesses should still keep reasonable support for related-party and connected-person payments.
What are the UAE transfer pricing disclosure thresholds?
The related-party disclosure schedule may apply when aggregate related-party transactions exceed AED 40 million, with categories above AED 4 million disclosed. The connected-person schedule may apply where payments or benefits to a connected person exceed AED 500,000.
Who must prepare a Master File and Local File in the UAE?
Master File and Local File documentation may be required where standalone revenue is AED 200 million or more, or where the business is part of a multinational group with consolidated revenue of AED 3.15 billion or more.
When must transfer pricing documentation be submitted to the FTA?
Master File and Local File documentation is generally maintained and provided within 30 days if requested by the FTA. It is not normally submitted with the Corporate Tax return.
What is the difference between related parties and connected persons?
Related parties are generally linked by ownership, control or family relationship. Connected persons include owners, directors, officers and their related parties. Both categories can affect Corporate Tax deductions and disclosure requirements.
Which transfer pricing methods does the UAE accept?
The UAE transfer pricing framework recognises methods aligned with OECD guidance, including comparable uncontrolled price, resale price, cost plus, transactional net margin method and profit split. Another method may be used where appropriate.
Do free zone companies have to comply with transfer pricing?
Yes. Free zone companies, including Qualifying Free Zone Persons, must comply with the arm’s length principle and maintain transfer pricing documentation where required.
Do loans between group companies count for transfer pricing?
Yes. Intercompany loans should be reviewed for arm’s length interest, loan terms, repayment terms, balances and disclosure treatment where applicable.
Can I adjust my transfer prices in the tax return?
Transfer pricing adjustments should be reviewed carefully before filing. Downward adjustments that reduce taxable income may require FTA approval, depending on the facts and applicable rules.
What are the penalties for transfer pricing non-compliance in the UAE?
Transfer pricing non-compliance can result in Corporate Tax adjustments, administrative penalties, document request issues and free zone tax status risk where QFZP conditions are affected.
What is a benchmarking study?
A benchmarking study compares a controlled transaction with comparable independent transactions or companies to support an arm’s length range for pricing.
Who must file a Country-by-Country Report in the UAE?
Country-by-Country Reporting applies to certain UAE-headquartered multinational groups that meet the applicable consolidated revenue threshold and reporting conditions.
Are Advance Pricing Agreements available in the UAE?
The FTA has published guidance for unilateral Advance Pricing Agreements. Businesses with significant recurring intercompany transactions may consider whether an APA route is appropriate.
