TSAC

Transfer Pricing

Price Your Related-Party Dealings with Confidence

Arm’s length analysis, documentation and benchmarking under UAE Corporate Tax and the OECD Guidelines, built on a clear understanding of how your group actually works.

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    Introduction

    Under UAE Corporate Tax, transactions with related parties and payments to connected persons must be priced at arm’s length, as if the parties were independent. This applies to cross-border dealings and to transactions within the UAE, including those between mainland and free zone companies.

    Good transfer pricing is more than a report filed once a year. It is a consistent account of where value is created in your group, reflected in your pricing policies, intercompany agreements, financial statements and tax returns. When those pieces line up, compliance becomes straightforward and your position is easy to explain.

    At TSAC, we combine transfer pricing, UAE Corporate Tax, IVS-compliant valuation and accounting in one team. Your transfer pricing is designed to be commercially sensible, properly documented and consistent with everything else you report, from the first analysis to any review by the FTA.

    // Our Services

    1.Transfer Pricing Policy & Planning

    Functional analysis and characterisation

    We study the functions, assets and risks of each entity to establish how it should be rewarded, whether as a service provider, distributor, principal or financing entity.

    Transfer pricing policy design

    We design clear, workable pricing policies for services, distribution, intellectual property and intra-group financing that your finance team can apply day to day.

    Intercompany agreements

    We draft and review intercompany agreements so the legal terms match how the business actually operates.

    2.Documentation & Compliance

    Master File and Local File

    We prepare transfer pricing documentation that meets the UAE requirements and OECD standards. That covers:
    • Master File and Local File for entities above the UAE thresholds
    • Documentation for Qualifying Free Zone Persons
    • Updates and roll-forwards in subsequent years

    Transfer Pricing Disclosure Form

    We prepare the disclosure filed with your Corporate Tax return and make sure it reconciles to your financial statements and documentation.

    Connected person payments

    We support the market value test for payments to owners, directors and other connected persons, including remuneration benchmarking for key management.

    3.Benchmarking & Specialist Analysis

    Benchmarking studies

    We carry out comparable company and comparable agreement searches using recognised databases, with a transparent search and accept-reject process that stands up to review.

    Intra-group financing

    We price shareholder and intercompany loans, guarantees and cash pooling, and assess whether funding should be treated as debt or equity in the first place.

    Management fees and services

    We analyse intra-group service charges, apply the simplified approach for low value-adding services where it fits, and support the benefit test.

    Business restructurings and intangibles

    We assess the transfer pricing of restructurings and transfers of functions, assets or IP, supported by our IVS-compliant valuation team.

    4. Review, Audit Support & Certainty

    Transfer pricing health checks

    We review your current arrangements and documentation, including files prepared by other advisers, and give you a clear, prioritised list of improvements.

    FTA enquiries and audits

    We prepare your responses, organise the supporting evidence and represent your position clearly during reviews and audits.

    Advance Pricing Agreements

    Where certainty matters, we support applications under the FTA’s Advance Pricing Agreement programme, from eligibility to agreement.

    Year-end adjustments

    We help you test results before year end and make any adjustments so the Corporate Tax computation reflects arm’s length outcomes.

    Why TSAC

    One team, complete view

    Transfer pricing, Corporate Tax, valuation and accounting work together, so your pricing, financial statements and tax return tell the same story.

    Practical and proportionate

    We match the depth of the work to the size and risk of each transaction, without unnecessary volume.

    Grounded in the rules

    Our analysis follows the UAE Corporate Tax Law, FTA guidance and the OECD Transfer Pricing Guidelines.

    Partner-led engagement

    Senior professionals lead your engagement from fact-finding to sign-off.

    Independent second opinions

    We regularly review transfer pricing files prepared by others, so you can rely on what you file.

    How We Work

    Understand

    We learn how your group operates, its transactions and what has already been documented.

    Analyse

    We map functions, assets and risks and characterise each entity.

    Benchmark

    We select the right method and test pricing against reliable comparables.

    Document

    We prepare policies, agreements, files and disclosures that are consistent and complete.

    Support

    We stay with you through year-end adjustments, FTA enquiries and annual updates.

    // FAQ's

    Frequently Asked Questions

    The arm’s length principle applies to all related-party transactions, whatever your size. Master File and Local File obligations apply only above set thresholds, but the disclosure form and the need to support your pricing can still apply. We help you work out exactly what is required.

    Yes. Transactions between related UAE entities, including between mainland and free zone companies, must also be at arm’s length.

    Yes. Meeting the transfer pricing rules and keeping supporting documentation is a condition for Qualifying Free Zone Person status, so it is central to keeping the 0% rate.

    Broadly, an owner, director or officer of the business, or someone related to them. Payments to connected persons must reflect market value to be deductible.

    Yes. We review existing files, benchmarking studies and policies and give you a clear view of their strengths and any gaps before you rely on them.

    FAQ's

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