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.
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
Free zone/mainland pairs, holding companies, family offices with portfolio entities, all transact on intercompany terms that require documentation.
Documentation prepared after an FTA request arrives is a very different, and much riskier, exercise than documentation prepared in advance.
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.
Undocumented related-party pricing is one of the most common warranty and price-adjustment items in GCC deal due diligence.
Every engagement starts with a risk assessment, then scopes only the documentation your business actually needs, not a one-size-fits-all package.
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.
The transfer pricing disclosure that accompanies your CT return once related-party transaction thresholds are exceeded, prepared accurately and consistently with your underlying documentation.
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.
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.
Independent comparables analysis using OECD-aligned methods, comparable uncontrolled price, cost-plus, TNMM, or profit split, selected on transaction type, not convenience.
Management fee, IP royalty, and cost-sharing arrangements reviewed and restructured to reflect genuine economic substance, protecting both your CT and QFZP position.
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.
Historic related-party pricing reviewed as part of financial due diligence, quantifying exposure before it becomes a buyer's negotiating leverage.
Reference only; thresholds and requirements are confirmed against your specific group structure and transaction profile at scoping stage.
| Threshold | Requirement |
|---|---|
| Any related-party transaction, any value | Must 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 category | Transfer pricing disclosure form required with the CT return |
| UAE-only group, related-party transactions > AED 200M | Local File required (Master File not required for UAE-only groups) |
| Multinational group, consolidated revenue ≥ AED 3.15B | Both Master File and Local File required |
Related-party transaction mapping and disclosure form preparation for the CT return.
Full Local File with benchmarking study for a single UAE entity above the AED 200M threshold.
Combined documentation for multinational groups above the AED 3.15B consolidated revenue threshold.
Related-party transactions and thresholds reviewed. Fixed-fee quote within 24 hours.
Full identification of intercompany loans, fees, royalties, and cost allocations.
Arm's-length benchmarking study and preparation of the required documentation.
Draft documentation walked through with you before finalisation.
Final documentation delivered, with audit support on standby if requested by the FTA.
Illustrative engagements based on the mandates we run. Client identities remain confidential in all cases.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.