Transfer Pricing Services
Transfer Pricing in UAE - Arm’s Length. Compliant. Audit-Proof.
Transfer Pricing (TP) is a key compliance area under the UAE Corporate Tax regime. Any transaction with related parties or connected persons whether within the UAE or cross-border must follow the Arm’s Length Principle (ALP) and align with OECD standards.
Transfer Pricing Compliance under UAE Corporate Tax
Under the UAE Corporate Tax framework, Transfer Pricing (TP) is central to how profits are allocated within business groups. Transactions with related parties or connected persons, whether domestic or cross-border, must be priced on a fair market basis and supported by robust documentation consistent with internationally accepted transfer pricing practices.
At Crestbourne Accounting and Tax Consultancy, we help businesses reduce TP risks, strengthen documentation, and defend pricing positions with confidence while ensuring structures remain commercially practical.
Understanding UAE Transfer Pricing Requirements
Arm’s Length Principle (ALP)
All related-party and connected-person transactions must be priced as if they were conducted between independent parties under comparable conditions.
Who Is Covered?
- Related Parties – Entities or individuals connected through ownership, control, or common management
- Connected Persons – Owners, directors, and relatives up to the 4th degree
Documentation Thresholds
Businesses with revenue of AED 200 million or more must maintain:
- Local File
- Master File
Even below the threshold, ALP compliance is mandatory.
Free Zone Entities
Qualifying Free Zone Persons must comply with Transfer Pricing rules to retain the 0% Corporate Tax benefit.
Why Strong Transfer Pricing Matters
- Reduces exposure to tax adjustments and penalties
- Strengthens governance and audit trails
- Ensures consistent pricing across group entities
- Supports sustainable profit and cost allocation
- Enhances global tax efficiency
- Prepares you for FTA audits and inquiries
Our Transfer Pricing Services
- TP risk areas and audit triggers
- Exposure to adjustments
- Documentation gaps and improvements
- Selecting the most appropriate TP methodology
- Benchmarking arm’s length pricing under OECD & UAE standards
- Developing clear TP policy documentation
- Reviewing intercompany agreements for economic substance and alignment
- Supporting implementation and periodic reviews
- Local File
- Master File
- CbCR support (notifications and compliance guidance)
- Pricing support for related party transactions
- Supply chain and value-chain alignment
- Profit attribution matters (including PE-related considerations)
- Audit/dispute support with tax authorities
Why Crestbourne?
“Arm’s Length. Future-Ready. Audit-Proof.”
- Strong UAE Corporate Tax + TP expertise
- Commercially practical and defensible policies
- End-to-end support: benchmarking → documentation → audit defense
- Big-firm quality with boutique flexibility
Book a Free Consultation
Get expert guidance on tax registration, filing, and compliance from Crest Bourne Advisory.
