Transfer pricing refers to the pricing of transactions between related parties or connected persons.

Under the UAE Corporate Tax framework, relevant transactions are expected to comply with the arm’s length principle. In simple terms, transactions between related parties should be priced consistently with what independent parties would have agreed under comparable circumstances.

Our Transfer Pricing Services

KBA can assist with:

• Related-party transaction identification
• Connected-person transaction review
• Transfer Pricing risk assessment
• Functional analysis
• Industry and transaction analysis
• Comparable analysis
• Arm’s length assessment
• Selection of appropriate Transfer Pricing methods
• Transfer Pricing policy development
• Transfer Pricing documentation
• Local File assistance
• Master File assistance
• Transfer Pricing disclosure support
• Corporate Tax Return support

The UAE framework recognises several Transfer Pricing methods, including the Comparable Uncontrolled Price, Resale Price, Cost Plus, Transactional Net Margin and Transactional Profit Split methods.

Transfer Pricing Documentation

Businesses may have specific documentation requirements depending on their circumstances. The FTA notes that certain businesses may be required to maintain Master File and Local File documentation, while relevant related-party information may need to be disclosed with the Corporate Tax Return.

Why Transfer Pricing Matters

Poorly documented related-party transactions can create tax risks during an FTA review. Businesses should therefore maintain appropriate records supporting the commercial rationale, pricing methodology and relevant transaction details.

Our approach combines accounting, tax and commercial analysis to help businesses develop defensible Transfer Pricing positions.

Practical Support for UAE Businesses

Whether your business has intercompany management fees, financing arrangements, service transactions, intellectual property arrangements, purchases, sales or other related-party dealings, our team can help assess the applicable Transfer Pricing requirements.

Contact KBA Accounting Services for professional Transfer Pricing support and Corporate Tax compliance in the UAE.