ZeroSync Accountants helps UAE businesses set, test and document related-party pricing so transactions with group companies, owners, directors and connected persons can be defended under the arm's length principle.
Best for UAE companies with related-party sales, management fees, cost recharges, loans, royalties, free zone transactions or connected-person payments.
The principle says that the price, margin and terms used between related parties should match what independent parties would accept in comparable circumstances.
In the UAE, this matters for related-party transactions and connected-person payments. A business should be able to explain the method, comparables, functional profile and documents that support the result.
Documentation records the position. Arm's length compliance tests whether the pricing itself is commercially defensible. ZeroSync connects both sides so the numbers, agreements and filings tell one story.
Review Transfer Pricing ServicesCompares a controlled price directly with a comparable independent transaction where reliable price data exists.
Works back from the resale price to an arm's length gross margin for the reseller.
Adds an arm's length mark-up to the supplier's costs, often used for services and routine support functions.
Tests net profit margin against comparable independent companies when direct price data is limited.
Splits combined profit based on how independent parties would share value in integrated arrangements.
The best method depends on the facts, data, functions, assets and risks. We document why the chosen method fits.
| Factor | What we examine | Why it matters |
|---|---|---|
| Product or service | Goods, services, finance, IP or support being priced. | Like should be compared with like. |
| Functions performed | Who performs sales, procurement, management, finance or support functions. | Profit should follow real value creation. |
| Assets used | Tangible assets, IP, systems, licences and financial assets. | Asset ownership and use can change expected returns. |
| Risks assumed | Inventory, credit, market, financing and contract risks. | Higher risk generally supports higher expected return. |
| Market conditions | Geography, industry, customer type, volume and economic conditions. | A margin in one market may not fit another. |
| Contract terms | Written agreements and actual conduct. | The FTA can look at substance, not only wording. |
ZeroSync focus: We document accepted and rejected comparables so the final benchmark looks reasoned, not arbitrary.
| Transaction | Pricing question | Evidence needed |
|---|---|---|
| Management fees | Is the service real and is the mark-up reasonable? | Service benefit evidence, cost base, mark-up benchmark, agreement. |
| Goods sold inside a group | Does the margin reflect each company's role? | Comparable margin analysis, invoices and contracts. |
| Loans and financing | Is the interest rate market-based? | Loan agreement, benchmark rates and repayment evidence. |
| Royalties and IP charges | Does the fee reflect the value of IP, brand or software? | IP ownership analysis, licence terms and royalty comparables. |
| Owner or director payments | Does the amount match market value for the role? | Role description, market pay support and approvals. |
| Free zone to mainland flows | Does pricing protect QFZP and taxable income positions? | Transaction mapping, QFZP assessment and agreements. |
A quick review can show whether your pricing is supported, under-documented or exposed before the FTA asks questions.
We identify related parties, connected persons, transaction types, values and accounting flows.
We document the functions performed, assets used and risks assumed by each party.
We choose the most appropriate method for each transaction and document the rationale.
We run or review comparable searches to support prices, margins, mark-ups or interest rates.
We align pricing policies, intercompany agreements, invoices and accounting treatment.
We refresh the analysis each period so the pricing stays current and defensible.
These links connect this page with the right corporate tax, transfer pricing and compliance cluster.
Corporate Tax Services DubaiCorporate Tax AdvisoryCorporate Tax Return FilingUAE Corporate Tax CalculatorDeadline Penalty CheckerQFZP AssessmentContact ZeroSyncTransfer Pricing Services DubaiTransfer Pricing Documentation UAEMaster File and Local File UAERelated Party Transactions Disclosure UAEQFZP Qualifying Income CheckerSet related-party pricing you can prove, before the next corporate tax filing or FTA review.
It means related parties and connected persons should price transactions as independent parties would in comparable circumstances. If pricing is not arm's length, the FTA can adjust taxable income to a supportable market result.
The method depends on the transaction, available data, functions, risks and assets. Common methods include CUP, resale price, cost plus, TNMM and profit split.
It is the range of results from comparable independent transactions or companies. If your price, margin or mark-up falls within that range, the position is easier to defend.
No. A fair intention still needs evidence. The method, comparable search, functional analysis and supporting documentation should show why the price is arm's length.
Yes. Free zone companies with related-party transactions should support arm's length pricing, especially where QFZP status, qualifying income or mainland transactions are involved.
At least annually, and whenever the business model, transaction value, functions, risks, agreements or market conditions change.
The FTA may adjust taxable income and additional corporate tax may become payable. Penalties or interest can also arise where the position is not supported.
Yes. ZeroSync can design a practical policy, pricing method, benchmarks and intercompany agreement approach so group pricing stays consistent year after year.
