Transfer Pricing
Price Your Related-Party Dealings with Confidence
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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.