With the introduction of UAE Corporate Tax, transfer pricing has moved from a theoretical concept to a live compliance obligation for UAE businesses with related-party transactions. Under Ministerial Decision No. 97 of 2023, UAE corporate taxpayers are required to ensure that transactions with related parties and connected persons are conducted at arm's length, and to maintain documentation demonstrating this.
CashLaw Global's transfer pricing practice assists UAE businesses in designing and documenting transfer pricing policies that meet the arm's length standard under UAE corporate tax law and the OECD Transfer Pricing Guidelines. We conduct economic analyses of related-party transactions, benchmark arm's length prices and margins using comparable market data, prepare transfer pricing documentation in the format required by the FTA, and advise on the restructuring of intercompany arrangements where the current pricing is not defensible.
Book a free consultation with our team and get expert guidance on transfer pricing in the UAE.
Book Free ConsultationYes. Transfer Pricing rules do not look solely at cross-border trade. They apply to all transactions conducted between "Related Parties" and "Connected Persons" within the UAE mainland and free zones, mandating that all inter-company exchanges strictly mirror the Arm's Length Principle.
Taxable persons must maintain a Master File (providing a global blueprint of the multinational group's business operations) and a Local File (detailing specific local entity transactional pricing) if their annual revenue meets or exceeds AED 200 million or if they belong to an MNE group with a consolidated revenue exceeding AED 3.15 billion.
Taxpayers must submit their complete Transfer Pricing documentation within 30 days from the date requested by the FTA. Because this window is short, attempting to compile these complex files retroactively after receiving an audit notice creates significant compliance risk.