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Transfer Pricing Advisory UAE
Documentation the FTA Will Accept

Every UAE business with related-party transactions, intercompany loans, management fees, IP royalties, cost-sharing between a free zone entity and its mainland affiliate, must price them at arm's length and be able to prove it within 30 days if the FTA asks. In 2026, transfer pricing sits near the top of the FTA's audit priority list. We prepare the risk assessments, benchmarking studies, and Local and Master Files that hold up under review.

In brief: Any related-party transaction requires arm's-length pricing. A disclosure form is required once related-party transactions exceed AED 40M in total or AED 4M in any category. A Local File is required for UAE-only groups above AED 200M in related-party transactions. A Master File plus Local File is required for multinational groups with AED 3.15B+ consolidated revenue. We handle risk assessment, benchmarking, documentation, and FTA audit support, led by a Chartered Accountant and CFA Charterholder, at fixed fees.

CFA & CA Qualified OECD BEPS Aligned Big 4 Trained Fixed Fee FTA Audit Support
Credentials CFA & ICAI Chartered Accountant Big 4 Trained UAE FTA Registered OECD-Aligned Methodology Local & Master File
Why This Matters Now

The FTA Is Actively Auditing Transfer Pricing in 2026

Until 2023 the UAE had no corporate tax and no reason to scrutinise intercompany pricing. That has changed completely. The FTA's risk-based audit cycles now treat related-party transactions as a priority area, precisely because so many UAE group structures, free zone plus mainland, holding company plus operating subsidiaries, family office plus portfolio companies, run on intercompany management fees, loans, and cost allocations that were never priced or documented on an arm's-length basis.

The exposure is real: a 30-day statutory window to produce evidence when the FTA asks, potential loss of Qualifying Free Zone Person status for five tax periods if related-party pricing fails scrutiny, and reassessment of taxable income on the FTA's terms rather than yours.

"Most UAE groups don't have a transfer pricing problem because their pricing is wrong. They have one because nobody ever wrote down why it's right, and that's exactly what the FTA is now asking for."

– Corvian Advisory, Tax Advisory Team

Every Group Structure Is Exposed

Free zone/mainland pairs, holding companies, family offices with portfolio entities, all transact on intercompany terms that require documentation.

The 30-Day Clock Starts on Request

Documentation prepared after an FTA request arrives is a very different, and much riskier, exercise than documentation prepared in advance.

QFZP Status Is On the Line

Arm's-length pricing is an explicit QFZP condition. Getting it wrong risks 9% tax on all income for five tax periods, not just the disputed transaction.

It Follows You Into M&A

Undocumented related-party pricing is one of the most common warranty and price-adjustment items in GCC deal due diligence.

What We Deliver

Transfer Pricing Services – In Full

Every engagement starts with a risk assessment, then scopes only the documentation your business actually needs, not a one-size-fits-all package.

Step One

Risk Assessment & Threshold Review

Identification of related-party transactions and connected persons, tested against the disclosure form, Local File, and Master File thresholds, so you know exactly what's required before we scope fees.

CT Return Filing

Disclosure Form Preparation

The transfer pricing disclosure that accompanies your CT return once related-party transaction thresholds are exceeded, prepared accurately and consistently with your underlying documentation.

Single Entity

Local File Preparation

A complete transfer pricing report covering your UAE entity's related-party transactions, functional analysis, and benchmarking, built to the standard the FTA expects to see, not a template with your logo on it.

Multinational Groups

Master File Preparation

For groups with consolidated revenue of AED 3.15 billion or more: the global operations, value chain, and intercompany financial arrangements documentation required alongside the Local File.

Economic Analysis

Arm's-Length Benchmarking Studies

Independent comparables analysis using OECD-aligned methods, comparable uncontrolled price, cost-plus, TNMM, or profit split, selected on transaction type, not convenience.

Structuring

Intercompany Agreement Review

Management fee, IP royalty, and cost-sharing arrangements reviewed and restructured to reflect genuine economic substance, protecting both your CT and QFZP position.

Under Review

FTA Audit & Dispute Support

Rapid-turnaround documentation and response support when the FTA has already made a request, working to the statutory 30-day window, alongside your tax lawyer where needed.

Deal-Linked

M&A Transfer Pricing Review

Historic related-party pricing reviewed as part of financial due diligence, quantifying exposure before it becomes a buyer's negotiating leverage.

Thresholds

UAE Transfer Pricing Documentation Thresholds

Reference only; thresholds and requirements are confirmed against your specific group structure and transaction profile at scoping stage.

ThresholdRequirement
Any related-party transaction, any valueMust be priced at arm's length; the FTA can request evidence at any time, with 30 days to respond
Related-party transactions > AED 40M total, or > AED 4M in any single categoryTransfer pricing disclosure form required with the CT return
UAE-only group, related-party transactions > AED 200MLocal File required (Master File not required for UAE-only groups)
Multinational group, consolidated revenue ≥ AED 3.15BBoth Master File and Local File required
Transparent Pricing

Fixed-Fee Transfer Pricing Engagements

Disclosure Form & Risk Assessment
AED 8,000 – 15,000

Related-party transaction mapping and disclosure form preparation for the CT return.

Local File – Most Common
AED 15,000 – 30,000

Full Local File with benchmarking study for a single UAE entity above the AED 200M threshold.

Master File + Local File
AED 30,000 – 60,000

Combined documentation for multinational groups above the AED 3.15B consolidated revenue threshold.

FTA audit and dispute support is scoped separately given the urgency and variable depth of these engagements, quoted within 24 hours of the request landing.
How We Work

Our Transfer Pricing Engagement Process

01
Risk Assessment

Related-party transactions and thresholds reviewed. Fixed-fee quote within 24 hours.

02
Transaction Mapping

Full identification of intercompany loans, fees, royalties, and cost allocations.

03
Benchmarking & Documentation

Arm's-length benchmarking study and preparation of the required documentation.

04
Review & Sign-Off

Draft documentation walked through with you before finalisation.

05
Filing & Ongoing Support

Final documentation delivered, with audit support on standby if requested by the FTA.

Illustrative Engagements

Transfer Pricing in Practice

Illustrative engagements based on the mandates we run. Client identities remain confidential in all cases.

FTA Audit Response
Trading Group · Dubai

Retrospective Local File Under a Live FTA Request

A Dubai trading group with mainland-free zone management fee arrangements received an FTA request for transfer pricing evidence, with no documentation in place. We prepared a full Local File with benchmarking, within the 30-day statutory window.

Outcome: Documentation accepted; no adjustment to the group's related-party pricing.
Master File Compliance
Manufacturing Group · UAE

First-Time Master & Local File for a Qualifying Group

A UAE-headquartered manufacturing group crossed the AED 3.15B consolidated revenue threshold for the first time. We built the group's first Master File alongside a UAE Local File, establishing the documentation baseline for future years.

Outcome: Filed ahead of deadline; template established for annual refresh at a reduced fixed fee.
QFZP Protection
Free Zone Holding Co. · Dubai

IP Royalty Benchmarking to Protect Free Zone Status

A free zone holding company licensing brand IP to its mainland operating entity had never benchmarked the royalty rate. We ran a relief-from-royalty benchmarking study and restructured the intercompany agreement to reflect an arm's-length rate.

Outcome: QFZP status preserved; royalty structure now defensible under audit.
FAQ

Transfer Pricing Advisory – Your Questions Answered

Does my UAE company need transfer pricing documentation?

If you transact with related parties, at any value, those transactions must be arm's length and evidenced within 30 days if the FTA asks. A disclosure form applies above AED 40M/AED 4M thresholds; a Local File above AED 200M for UAE-only groups.

What is the difference between the disclosure form, Local File and Master File?

The disclosure form is a CT-return summary. The Local File is a full report on your UAE entity's related-party transactions. The Master File covers the global group and is required only above AED 3.15B consolidated revenue.

What counts as a related-party transaction?

Intercompany loans and guarantees, management and service fees, IP and royalty payments, shared cost allocations, and goods transfers between entities under common ownership, including free zone-mainland pairs.

What happens if the FTA requests documentation I don't have?

You have 30 days to produce it. Without a benchmarking study already in place, that deadline is very difficult to meet with defensible documentation, which is when penalty exposure and unfavourable assessment risk rise sharply.

How much does a transfer pricing benchmarking study cost?

AED 8,000 to AED 60,000 depending on scope. Disclosure form and risk assessment from AED 8,000; a Local File AED 15,000–30,000; Master File plus Local File AED 30,000–60,000. Fixed fee, agreed before work begins.

How is an arm's length price determined?

Using OECD-aligned methods, comparable uncontrolled price, cost-plus, resale price, TNMM, or profit split, benchmarked against independent comparables. The method is chosen for the transaction type, not convenience.

Does transfer pricing affect Qualifying Free Zone Person status?

Yes. Arm's-length related-party pricing is an explicit QFZP condition. Failing it risks 9% tax on all income for at least five tax periods, not just the disputed transaction.

How long does transfer pricing documentation take to prepare?

Disclosure form and risk assessment: 1–2 weeks. Local File: 3–4 weeks. Master File plus Local File: 4–6 weeks. Urgent FTA-response engagements are scoped to the 30-day statutory deadline.

Do you provide support during an FTA transfer pricing audit?

Yes. We prepare or remediate documentation under audit timelines and respond to FTA information requests, working alongside your tax lawyer where litigation risk is present.

How does transfer pricing come up in M&A transactions?

Historic related-party pricing becomes a diligence and warranty item; undocumented positions are a common source of price chips. See our financial due diligence service.

Is this different from general UAE Corporate Tax compliance?

Yes. CT registration and filing address your overall tax position; transfer pricing is a distinct economics-based analysis of related-party transactions. See our UAE Corporate Tax Advisory page for the broader compliance picture.

Related-Party Transactions Need Documentation That Holds Up

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