Defending Intra-Group Services: A Practical Guide to Transfer Pricing Compliance
Understanding the Benefit Test, Arm’s Length Pricing, and Audit Risks for Multinational Businesses Global business operations have become increasingly interconnected. Multinational enterprises (MNEs) routinely share expertise, resources, and support functions across multiple jurisdictions. Whether it is management oversight, IT support, accounting assistance, human resources, or strategic advisory services, companies often rely on intra-group services to […]
OECD Transfer Pricing Update: What UAE Businesses Need to Know
What UAE Businesses Need to Know About Transfer Pricing Documentation and Management Fees The Organization for Economic Co-operation and Development (OECD) has released a public consultation document proposing revisions to Chapter VII of the OECD Transfer Pricing Guidelines relating to intra-group services. The consultation seeks to modernise existing guidance and provide greater clarity on how […]
Bahrain’s New DMTT Transfer Pricing Rules Explained
Bahrain Introduces Transfer Pricing Guide Under DMTT: What Multinational Businesses Need to Know in 2026 Bahrain has taken a significant step in strengthening its international tax framework with the release of the DMTT Transfer Pricing Guide in June 2026. The guidance provides multinational enterprise (MNE) groups with a structured approach to applying transfer pricing principles […]
Transfer Pricing Benchmarking Study UAE
Transfer Pricing Benchmarking Study UAE: How It Works and When You Need One A transfer pricing benchmarking study compares your intercompany pricing against transactions between independent companies to confirm the pricing meets the arm’s length standard. In the UAE, the study must be conducted at the transactional level — not at the entity’s overall profitability […]
UAE Transfer Pricing Documentation Master File and Local File Requirements Explained (2025)
UAE businesses with standalone revenue of AED 200 million or more — or those that are part of an MNE group with global consolidated revenue of AED 3.15 billion or more — must prepare and maintain a Master File and Local File under Ministerial Decision No. 97 of 2023. These documents do not need to be filed with the […]
The Arm’s Length Principle in UAE Transfer Pricing: What It Means for Your Business
The arm’s length principle (ALP) requires every transaction between related parties in the UAE to be priced as if the two parties were completely independent. It is mandatory under Article 34 of the Corporate Tax Law — and it applies to intra-UAE deals too, including transactions between a mainland company and its free zone affiliate. […]
UAE Transfer Pricing 2026 : Compliance Guide for FY 2025
Transfer pricing in the UAE is governed by Articles 34–36 of the Corporate Tax Law and the FTA’s Transfer Pricing Guide (October 2023). All transactions between related parties must comply with an arm’s length — including intra-UAE transactions between a mainland entity and its free zone affiliate. Companies with UAE revenue of AED 200 million or more, or group consolidated revenue […]
Transfer Pricing for Retail Franchise Operations in UAE
Royalty Structures, Master Franchise vs. Sub-Franchise, and GCC Benchmarking The rapid expansion of global and regional retail brands has made the UAE one of the most active franchise markets in the Middle East. As a result, transfer pricing in UAE retail franchise operations has become a critical compliance and tax risk area for multinational groups, […]
How UAE Transfer Pricing Policies Align with OECD Guidelines and BEPS 2.0
In a global economy where cross-border transactions are constantly rising and digital business models are rapidly evolving, effective transfer pricing frameworks have never been more critical. For multinational enterprises operating in the UAE — particularly in hubs like Dubai, Abu Dhabi Global Market (ADGM), and Free Zones — understanding how transfer pricing in UAE aligns […]