Transfer Pricing
Arm's-length compliance for related-party transactions. Master file, local file, benchmarking studies, the transfer pricing disclosure form, and arm's-length policy design under UAE Corporate Tax and OECD rules.
Why Transfer Pricing?
With the arrival of UAE Corporate Tax, transfer pricing has become a live compliance obligation for businesses that transact with related parties or connected persons. The rules follow the internationally recognised arm's-length principle and OECD Transfer Pricing Guidelines: transactions within a group, or with owners and their relatives, must be priced as they would be between independent parties — and you must be able to evidence it.
BIFI Partners helps you meet these obligations without disruption. We prepare the transfer pricing disclosure form that accompanies the Corporate Tax return, and — where the size thresholds are met — the master file and local file documentation, supported by benchmarking studies that establish an arm's-length range from comparable market data.
Just as importantly, we help you design defensible transfer pricing policies up front — for management fees, financing, royalties, and the supply of goods and services between related entities — so your structure is both commercially sensible and compliant. Getting this right protects you from adjustments, penalties, and double taxation, and gives you certainty when you transact across borders, including with our sister firm's clients in India.
Arm's-Length
OECD-Aligned Pricing
Master & Local
File Documentation
Benchmarking
Defensible Comparables
Disclosure Form
Return-Ready
Transfer Pricing services in detail
Comprehensive coverage across every aspect of transfer pricing — tailored for your business.
Transfer Pricing Documentation (Master & Local File)
Where your group's revenue and your entity meet the prescribed thresholds, we prepare the master file (the group's global picture) and the local file (your UAE entity's related-party transactions and pricing analysis) to the standard the FTA expects — ready to produce on request within the required timeframe.
Benchmarking Studies
We establish the arm's-length range for your related-party transactions using recognised databases and methods — comparable uncontrolled price, cost-plus, resale-price, transactional net margin, or profit-split — and document why the selected method and comparables are appropriate to your facts.
Transfer Pricing Disclosure Form
We prepare the transfer pricing disclosure form that accompanies your Corporate Tax return, accurately reporting related-party and connected-person transactions and the methods applied — the baseline obligation that applies well below the documentation thresholds.
Related-Party & Connected-Person Review
We map your related parties and connected persons (including owners, directors, and their relatives, and commonly controlled entities), identify which transactions are in scope, and flag arrangements — such as owner remuneration and intra-group charges — that need an arm's-length basis.
Arm's-Length Policy Design
We help you set practical, defensible pricing policies for management and service fees, intra-group financing, royalties, and goods — aligning your commercial reality with the arm's-length principle so your documentation supports your day-to-day dealings.
Country-by-Country Reporting Support
For UAE-headquartered multinational groups above the consolidated-revenue threshold, we support country-by-country reporting and notification obligations, coordinating with your group's wider compliance.
Our transfer pricing process
Scoping & Related-Party Mapping
We identify your related parties and connected persons and catalogue the controlled transactions that fall within the transfer pricing rules.
Functional Analysis
We analyse the functions performed, assets used, and risks borne by each party to characterise the transactions and select the appropriate pricing method.
Benchmarking
We run benchmarking studies against comparable data to establish the arm's-length range and test your existing pricing against it.
Documentation & Disclosure
We prepare the disclosure form and, where required, the master and local files — fully referenced and aligned to your Corporate Tax return.
Policy & Monitoring
We help embed compliant pricing policies and review them as your group and transactions evolve, keeping documentation current.
Built for businesses like yours
Common questions about transfer pricing
If you transact with related parties or connected persons, the transfer pricing rules apply and you must at least complete the disclosure form with your Corporate Tax return. Full master file and local file documentation is required only where your group's revenue and your entity meet the prescribed thresholds. We assess exactly what applies to you so you neither over- nor under-comply.
Related parties broadly include entities and individuals linked by ownership or control — group companies, and parties holding a significant interest. Connected persons include the business owners, directors and officers, and their relatives, as well as their related parties. Transactions with all of these — including owner remuneration and intra-group charges — must meet the arm's-length standard. We map these relationships precisely for you.
It requires that transactions between related parties be priced as if they were between independent parties dealing at market rates. In practice you select an appropriate method (such as comparable uncontrolled price or transactional net margin), benchmark against comparable data to find an arm's-length range, and ensure your pricing falls within it — supported by documentation.
Meeting transfer pricing requirements is one of the conditions a Qualifying Free Zone Person must satisfy to keep the 0% rate on qualifying income. A free zone entity that transacts with related parties must have appropriate documentation and arm's-length pricing; failing this can jeopardise QFZP status. We make sure your transfer pricing supports, rather than undermines, your free zone position.
The disclosure form is filed with your Corporate Tax return. Master and local files generally must be maintained and produced to the FTA on request within a set period (commonly 30 days). Because the analysis takes time to do well, we prepare documentation alongside your year-end rather than waiting for a request.
Yes. Through our sister firm EQX Partners in India, we coordinate transfer pricing for groups operating across both countries — aligning methods, benchmarking, and documentation on both sides of the transaction to reduce the risk of adjustments and double taxation.
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