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Transfer Pricing Services in UAE

Best Transfer Pricing Services in UAE — Compliance, Documentation & Advisory

As UAE companies expand across borders and within free zones, managing intercompany transactions has become a top regulatory priority. Since the introduction of UAE Corporate Tax in 2023, transfer pricing rules now apply to businesses of all sizes — including SMEs, free zone companies, and startups with related party transactions.

 

At NR Doshi & Partners, we provide end-to-end transfer pricing advisory and compliance services across Dubai, Abu Dhabi, Sharjah, JAFZA, SAIF Zone, and RAK Free Zone. With over 40 years of experience serving UAE businesses, our team helps you stay compliant, avoid penalties, and maintain robust documentation.

What is Transfer Pricing?

Transfer pricing refers to the prices set for transactions between related parties — such as a parent company and its subsidiary, or two entities with common ownership. These transactions can involve goods, services, loans, intellectual property, and more.

The core principle governing transfer pricing is the arm’s length principle. This requires that transactions between related parties are priced as if they were conducted between independent parties in a free market. Regulators use this standard to prevent profit shifting and tax avoidance.

The Arm's Length Principle Explained

Under the arm’s length principle, if Company A in the UAE sells products to its affiliate Company B in another country, the price charged should reflect fair market value — not an artificially inflated or deflated price designed to shift profits to a lower-tax jurisdiction.

 

The UAE Federal Tax Authority (FTA) requires companies to demonstrate that their related party transactions comply with this principle, supported by appropriate documentation.

Transfer Pricing Rules in the UAE

The UAE introduced formal transfer pricing regulations as part of Federal Decree-Law No. 47 of 2022 on Corporate Tax. Key requirements include:

      • Related party transactions must comply with the arm’s length principle
      • Qualifying companies must prepare and maintain transfer pricing documentation
      • Businesses must disclose related party transactions in their corporate tax return
      • Certain large multinationals must file a Country-by-Country Report (CbCR)
Who Must Comply?

Transfer pricing rules apply to businesses that:

      • Have transactions with related parties or connected persons
      • Are part of a multinational enterprise (MNE) group
      • Generate revenues above the thresholds set by the FTA
      • Are free zone entities with transactions with mainland related parties

Even smaller businesses with intercompany loans, service fees, or shared cost arrangements may be subject to TP rules.

Looking for Transfer Pricing Services in UAE?

NR Doshi & Partners provides trusted transfer pricing advisory and compliance support for businesses of all sizes across Dubai, Abu Dhabi, Sharjah, and UAE free zones.

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Required Documentation — Master File, Local File & CbCR

Document

Purpose

Master File

Overview of the MNE group’s global business, TP policies, and financial data

Local File

Detailed analysis of the UAE entity’s related party transactions

Country-by-Country Report (CbCR)

Revenue, profit, tax, and employee data for each jurisdiction — for large MNEs

Disclosure Form

Summary of related party transactions included in the corporate tax return

Our Transfer Pricing Services

NR Doshi & Partners offers a full suite of transfer pricing services tailored to UAE businesses:

TP Advisory & Policy Design
      • Review existing intercompany agreements and pricing structures
      • Design compliant transfer pricing policies aligned with OECD guidelines
      • Advise on structuring related party transactions for compliance and efficiency
      • Guidance for new UAE market entrants setting up intercompany structures
Documentation Preparation
      • Preparation of Master File and Local File documentation
      • Disclosure form completion for corporate tax filings
      • Country-by-Country Reporting (CbCR) preparation and submission
      • Annual review and update of existing TP documentation
Benchmarking & Economic Analysis
      • Comparable uncontrolled price (CUP) and other OECD method analysis
      • Database benchmarking studies to support arm’s length pricing
      • Profit margin analysis and functional analysis of related parties
FTA Audit Support
      • Representation during FTA transfer pricing inquiries and audits
      • Review and gap analysis of existing TP documentation
      • Remediation support to address documentation deficiencies
      • Advance pricing agreement (APA) guidance

Industries We Serve

Our transfer pricing expertise serves a diverse range of UAE businesses:

 

Industry / Business Type

Typical TP Issue

SMEs with foreign affiliates

Management fees, loans, shared services

Startups with offshore parent/investor

IP licensing, R&D cost sharing

Free Zone Companies

Goods trading, service charges between mainland & free zone entities

Trading Companies

Pricing of goods purchased from/sold to related parties

E-commerce Businesses

Platform fees, logistics, fulfilment charges to related parties

Manufacturing Companies

Raw material pricing, contract manufacturing arrangements

Professional Services Firms

Intercompany fee arrangements, seconded staff

Our Coverage Across UAE

We provide transfer pricing services to businesses located across the UAE, including:

 

Location

Business Types Served

Dubai (Mainland)

SMEs, MNEs, trading companies, professional services

JAFZA (Jebel Ali Free Zone)

Manufacturing, logistics, trading companies

SAIF Zone (Sharjah)

SMEs, industrial, trading, and logistics companies

RAK Free Zone

Startups, e-commerce, technology companies

Abu Dhabi

Oil & gas, financial services, construction, government-linked

Sharjah (Mainland)

Manufacturing, trading, retail businesses

Our Process

We follow a clear, structured approach to transfer pricing compliance:

  1. Initial Consultation — We review your business structure, related party relationships, and existing intercompany agreements.
  2. Gap Analysis — We identify documentation gaps, non-compliant pricing, and areas of regulatory risk.
  3. Functional Analysis — We map out functions, assets, and risks of each related party to determine the most appropriate TP method.
  4. Benchmarking Study — Where required, we conduct economic analysis using international databases to establish arm’s length ranges.
  5. Documentation Preparation — We prepare Master File, Local File, Disclosure Form, and CbCR as applicable.
  6. Review & Sign-off — All documentation is reviewed by our senior advisors and signed off for accuracy and compliance.
  7. Ongoing Monitoring — We provide annual reviews to ensure documentation remains current with changing regulations and business circumstances.
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Why choose NR Doshi & Partners’ services of VAT refund in UAE?

Trusted by UAE Businesses for Over 40 Years

      • 40+ years of audit, tax, and advisory experience in the UAE since 1985
      • Deep understanding of FTA regulations and OECD transfer pricing guidelines
      • Specialists in UAE Corporate Tax compliance including transfer pricing obligations
      • Serving clients across Dubai, Abu Dhabi, Sharjah, and all major free zones
      • Trusted advisors to SMEs, multinationals, free zone companies, and startups
      • Strong compliance framework with structured processes and quality review
      • Practical, plain-English advice — not just technical jargon
      • End-to-end support: from initial consultation to FTA audit representation

Other than VAT refunds, we also assist our clients in multiple activities under our VAT consultancy services. Our VAT refund consultants in Dubai provide VAT registration services, Vat deregistration in UAE, VAT Return Filing, Vat accounting, handling disputes, penalties, audits, and health checks. We keep you VAT compliant always.

FAQs

Transfer pricing rules in the UAE apply to businesses that have transactions with related parties or connected persons. This includes companies within a group structure, businesses with foreign affiliates, and entities sharing common ownership. Even SMEs with intercompany loans or management fees may be subject to TP obligations under UAE Corporate Tax law.

UAE companies may be required to prepare a Master File, Local File, and Country-by-Country Report (CbCR) depending on their size and MNE group revenue. In addition, all companies with related party transactions must complete a Disclosure Form as part of their corporate tax return. NR Doshi & Partners can help you determine which documents apply to your business.

The arm's length principle requires that transactions between related parties are priced as if they were conducted between independent, unrelated parties in similar circumstances. This is the global standard for transfer pricing and is enforced by the UAE Federal Tax Authority (FTA). Non-compliance can result in tax adjustments and significant penalties.

Yes. Free zone companies — including those in JAFZA, SAIF Zone, and RAK Free Zone — are subject to UAE Corporate Tax and transfer pricing regulations. If a free zone entity has transactions with related parties on the UAE mainland or in other jurisdictions, those transactions must comply with the arm's length principle and be properly documented.

The UAE Federal Tax Authority can impose financial penalties for failure to maintain required transfer pricing documentation, failure to disclose related party transactions, and non-arm's length pricing that results in a reduction in taxable income. Penalties can also arise from failure to submit a Country-by-Country Report on time. Early compliance is strongly advisable.

A Country-by-Country Report is a document required from large multinational enterprises (MNEs) with consolidated group revenue above a specified threshold. It provides tax authorities with information about the group's revenue, profit, taxes paid, employees, and assets in each jurisdiction. The UAE has implemented CbCR requirements in line with OECD BEPS Action 13 standards.

NR Doshi & Partners provides end-to-end transfer pricing services including policy design, documentation preparation (Master File, Local File, CbCR), benchmarking studies, FTA audit support, and ongoing compliance reviews. With over 40 years of experience in UAE tax and accounting, our team delivers practical, regulatory-compliant solutions for businesses across Dubai, Abu Dhabi, Sharjah, and major UAE free zones.

Transfer pricing documentation should be reviewed and updated annually to reflect changes in business operations, transaction volumes, pricing policies, and regulatory requirements. The UAE FTA expects documentation to be current at the time of filing. NR Doshi & Partners provides annual TP review services to ensure your documentation remains compliant.

Speak with Our Transfer Pricing Experts

Receive practical guidance on transfer pricing compliance, documentation, and regulatory requirements in the UAE.

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