Tax Services
Transfer Pricing in the UAE
Transfer Pricing documentation, benchmarking and international reporting aligned with UAE Corporate Tax law and OECD guidelines.
Book a Free ConsultationUnder UAE Corporate Tax, transactions between related parties and connected persons must follow the arm’s-length principle. Qualifying businesses must maintain Transfer Pricing documentation — including a Local File and Master File — and disclose related-party dealings.
Nexus Wise designs compliant TP policies, prepares robust documentation and benchmarking, and supports your international reporting so your intercompany pricing stands up to FTA scrutiny.
Transfer Pricing documentation
What you need depends on your revenue and group size.
What we offer
Local File & Master File Preparation
Documentation that evidences arm’s-length pricing across your related-party transactions, in line with FTA requirements.
Benchmarking Study
Comparable analyses using recognised databases to defend your pricing positions.
Transfer Pricing Advisory
Policy design, intercompany agreements and practical guidance on related-party dealings.
International Reporting (CbCR)
Country-by-Country Reporting and disclosures for groups that meet the thresholds.
Who needs Transfer Pricing compliance
If you transact with related parties or connected persons, the arm’s-length principle applies — and documentation may be mandatory.
- Companies transacting with related parties (group companies or common ownership)
- Dealings with connected persons — owners, directors and their relatives
- Free-zone entities — the rules apply right across the UAE
- Both cross-border and domestic related-party transactions
The documentation tiers
- Disclosure form — filed with the Corporate Tax return where thresholds are met
- Local File — your UAE related-party transactions and pricing analysis
- Master File — a group-wide overview of the multinational
- Country-by-Country Report (CbCR) — for large multinational groups
When a Local & Master File are required
Thresholds are indicative — we confirm exactly what applies to you.
- Your revenue in the tax period is AED 200 million or more, or
- You belong to a multinational group with consolidated revenue of AED 3.15 billion or more
- CbCR applies to UAE-headquartered groups at the AED 3.15 billion level
How we set and defend your pricing
- Select the right OECD method (CUP, resale-price, cost-plus, TNMM or profit-split)
- Benchmarking studies using recognised databases
- Intercompany agreements and policy design
- Documentation built to withstand FTA review
Why it matters
Arm’s-length compliance
Meet the UAE’s transfer-pricing rules and avoid adjustments and penalties.
Defensible documentation
Benchmarking and files designed to withstand FTA review.
Cross-border alignment
Consistency with OECD standards and your global group policy.
Frequently asked questions
Who needs Transfer Pricing documentation in the UAE?
Any business with related-party or connected-person transactions must apply the arm’s-length principle and complete the disclosure form with its Corporate Tax return. A Local File and Master File become mandatory once the size thresholds are met.
What is the arm’s-length principle?
Prices charged between related parties must match what independent parties would agree under comparable conditions — supported by benchmarking evidence.
What’s the difference between a Local File and a Master File?
The Local File details your UAE related-party transactions and how they’re priced; the Master File gives a group-wide picture of the multinational’s structure, activities and policies.
When do the Local and Master Files become mandatory?
Broadly, when your revenue reaches AED 200 million in the tax period, or you’re part of a multinational group with consolidated revenue of AED 3.15 billion or more. We confirm your position.
What is Country-by-Country Reporting (CbCR)?
A group-level report required of large multinational groups (consolidated revenue of AED 3.15 billion or more), typically filed by the UAE parent. We handle the notification and report.
Do free-zone companies need TP compliance?
Yes. Transfer Pricing rules apply across the UAE — including free-zone entities — wherever related-party transactions exist.
Which pricing methods are accepted?
The recognised OECD methods: comparable uncontrolled price, resale price, cost plus, transactional net margin (TNMM) and profit split. We select and justify the most appropriate one.
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