Transfer Pricing

Every defensible transfer pricing position starts with a clear FAR analysis. We map which entities perform significant functions, bear economic risk, and hold key assets, and translate that into a pricing position that reflects actual substance. This analysis forms the foundation for both documentation and any dispute response.

UAE regulations require a Master File and Local File when prescribed thresholds are met. We prepare and review these across jurisdictions, ensuring consistency between the group narrative in the Master File and entity-level positions in each Local File. This harmonisation matters: inconsistency between the two is a common trigger for FTA scrutiny. Where documentation spans multiple countries, we work alongside local advisors to maintain alignment and avoid contradictions across the group's TP positions.

For qualifying groups, we manage CbCR preparation and submission, including notification obligations and consistency checks against the Master File and Local Files.

We conduct benchmarking analyses for the full range of intercompany transactions, including goods, services, royalties, financing and management fees. Comparable sets are built on commercial logic and economic substance, not mechanical database filters, and are prepared to a standard that supports both the documentation and regulatory scrutiny.

The UAE CT Return requires disclosure of related party and connected person transactions. We identify the relevant relationships, confirm transactions requiring disclosure, and prepare the supporting schedules, aligned to the transfer pricing documentation for consistency.

Where a group is reorganising its operating model, changing supply chain routes, or shifting functions between entities, the transfer pricing consequences need to be addressed as part of the transition. We evaluate the TP implications of proposed restructurings, advise on exit charges where applicable, and document the before and after position.

Where certainty is the priority, we advise on the viability of Advance Pricing Agreements with the FTA and manage the end-to-end process, covering unilateral and bilateral APAs. Where double taxation arises despite an applicable treaty, we coordinate and manage Mutual Agreement Procedure filings between the relevant competent authorities. For groups already in a dispute with the FTA, we provide representation through the review process and before the Tax Disputes Resolution Committee, including economic counter-analysis and technical submission preparation.