Since the introduction of UAE Corporate Tax, transfer pricing in the UAE has become a core compliance requirement for any business that transacts with related parties or connected persons. At ANCPA Auditing LLC — a licensed CPA firm and FTA-registered tax agent in Dubai — we help companies apply the arm’s length principle, prepare compliant documentation, and avoid penalties under Federal Tax Authority (FTA) rules.
What Is Transfer Pricing?
Transfer pricing refers to the prices set on transactions between related parties — for example, between a parent company and its subsidiary, or between businesses under common control. Under the UAE Corporate Tax Law, these transactions must follow the arm’s length principle: they must be priced as if the parties were independent and dealing in the open market.
UAE Transfer Pricing Rules Under Corporate Tax
Transfer pricing is governed by Articles 34 to 36 of the UAE Corporate Tax Law (Federal Decree-Law No. 47 of 2022), aligned with the OECD Transfer Pricing Guidelines. Key requirements include:
Arm’s length principle — all related-party and connected-person transactions must reflect fair market value.
Accepted methods — Comparable Uncontrolled Price (CUP), Resale Price, Cost Plus, Transactional Net Margin Method (TNMM), and Profit Split.
Related parties & connected persons — defined under Article 35, covering group entities, owners, directors, and their relatives.
Transfer pricing is closely linked to your corporate tax registration and your annual corporate tax return.
Who Must Comply With UAE Transfer Pricing?
All taxable persons with related-party transactions must apply the arm’s length principle. Additional documentation obligations depend on size (per Ministerial Decision No. 97 of 2023):
Transfer Pricing Disclosure Form — filed with the corporate tax return where related-party transactions exceed the prescribed threshold.
Master File & Local File — required if the business is part of a multinational group with consolidated revenue of AED 3.15 billion or more, or if the taxable person’s own revenue is AED 200 million or more in the relevant tax period.
Country-by-Country Reporting (CbCR) — for large multinational groups with consolidated revenue of AED 3.15 billion or more.
Transfer Pricing Documentation We Prepare
Master File and Local File preparation (OECD-aligned)
Benchmarking and comparability (arm’s length) analysis
Transfer Pricing Disclosure Form support for your tax return
Transfer pricing policy design and intercompany agreements
Country-by-Country Reporting (CbCR) assistance
Our Transfer Pricing Services in Dubai & the UAE
As a licensed CPA firm, we provide end-to-end transfer pricing services in Dubai and across the UAE:
Transfer pricing risk assessment and health checks
Functional, asset and risk (FAR) analysis
Selection and application of the most appropriate method
Preparation and review of compliant documentation
Support during FTA audits and queries
We align transfer pricing with your wider compliance — including audit and assurance and VAT obligations.
Why Choose ANCPA Auditing for Transfer Pricing
FTA-registered tax agent and licensed UAE CPA firm
25+ years of professional experience
OECD-aligned methodology and audit-ready documentation
Practical deliverables that stand up to FTA review
Explore our full range of tax services in the UAE or contact our team for a free consultation.
Frequently Asked Questions
Is transfer pricing mandatory in the UAE?
Yes. Any taxable person with related-party or connected-person transactions must apply the arm’s length principle under the UAE Corporate Tax Law, and larger businesses must also maintain a Master File and Local File.
What is the Master File and Local File threshold in the UAE?
A taxable person must maintain a Master File and Local File if it belongs to a multinational group with consolidated revenue of AED 3.15 billion or more, or if its own revenue is AED 200 million or more in the relevant tax period.
What is the Transfer Pricing Disclosure Form?
It is a form filed with the corporate tax return that discloses related-party transactions and confirms compliance with the arm’s length principle.
What are the penalties for non-compliance?
Non-compliance can lead to FTA penalties, adjustments to taxable income, and additional corporate tax. Maintaining proper documentation is your best protection.
Need help with transfer pricing in the UAE? Speak directly with a licensed CPA today — book your free consultation.
