Transfer Pricing

Transfer Pricing Compliance & Advisory in UAE

With the introduction of UAE Corporate Tax, Transfer Pricing has become a critical compliance requirement for businesses engaging in related-party transactions. The UAE Corporate Tax framework brings greater transparency and alignment with international tax standards. Under UAE Corporate Tax Law (Federal Decree-Law No. 47 of 2022), businesses must follow the OECD Transfer Pricing Guidelines to ensure all intercompany transactions are conducted at arm’s length. ZBS provides reliable Transfer Pricing advisory and compliance services to help businesses meet regulatory requirements and avoid penalties.

What is Transfer Pricing?

Transfer Pricing refers to the pricing of transactions between related entities such as parent companies, subsidiaries, sister companies, or group entities within a multinational structure. These transactions may include:

• Sale or purchase of goods and materials
• Management, IT, or technical service fees
• Licensing or use of intellectual property
• Financial transactions such as loans and guarantees

Transfer Pricing Documentation Requirements

• Master File – Overview of the group structure, business activities, and pricing policies
• Local File – Details of UAE entity transactions with benchmarking support
• Country-by-Country Report (CbCR) – Applicable to multinational groups with global revenues above AED 3.15 billion

Transfer Pricing & UAE Corporate Tax

Transfer Pricing directly impacts the calculation of taxable income under UAE Corporate Tax.