ZeroSync Accountants prepares FTA-ready transfer pricing documentation for UAE businesses, including the disclosure form and Master File and Local File support where the thresholds apply.
Best for UAE companies with related-party transactions, connected-person payments, free zone structures, cross-border groups or disclosure obligations.
Transfer pricing is not complete just because the price looks reasonable. A business must also be able to prove that related-party and connected-person transactions were priced at arm’s length.
UAE transfer pricing documentation is best understood in three layers: the disclosure form, the Local File and the Master File. Which layers apply depends on the business size, group status and transaction values.
| Layer | Purpose |
|---|---|
| Disclosure form | Summary schedule filed with the corporate tax return |
| Local File | Detailed analysis of UAE controlled transactions |
| Master File | Group-level transfer-pricing and business overview |
| Benchmarking | Evidence that pricing falls within an arm’s length range |
| Trigger | Threshold | Result |
|---|---|---|
| Taxable person revenue | At least AED 200 million in the tax period | Master File and Local File required |
| MNE group revenue | At least AED 3.15 billion consolidated group revenue | Master File and Local File required |
| Below both thresholds | No full file requirement in many cases | Disclosure form may still apply if transaction thresholds are met |
ZeroSync sizes the obligation first, so you do not pay for documentation you do not need or skip documentation that should already be maintained.
Summarises related-party and connected-person transactions, values and methods as part of the corporate tax return process.
Analyses controlled transactions, functions, assets, risks, method selection and benchmarking for the UAE entity.
Explains the group’s structure, business, value drivers, intangibles, financing and overall tax position.
Documents who does what, who owns what and who bears which risks across related parties.
Uses independent comparables to support the arm’s length nature of the pricing or margins.
Keeps the support file organised so it can be produced quickly if the FTA requests it.
Contemporaneous documentation is prepared around the time of the transactions and return, not reconstructed after a query arrives. It carries more weight because it shows the business had a supportable position when it filed.
Documentation prepared only after an FTA notice can look reactive and weak. ZeroSync prepares and refreshes documentation with each tax period so your evidence is ready before any review begins.
A disclosure form, benchmarking study and functional analysis should agree with the accounts, corporate tax return and intercompany agreements. Inconsistency is one of the easiest ways to trigger questions.
| Step | What we do | Outcome |
|---|---|---|
| 1. Scoping | Confirm whether you need disclosure only or full files | Right-sized documentation scope |
| 2. Data gathering | Collect intercompany transactions, agreements and financials | Complete evidence base |
| 3. Functional analysis | Document functions, assets and risks | Clear basis for method selection |
| 4. Benchmarking | Test pricing or margins against comparables | Arm’s length evidence |
| 5. Drafting and review | Prepare the disclosure form and files where required | Consistent FTA-ready documentation |
| 6. Upkeep | Refresh documents each tax period | Contemporaneous records |
Transfer pricing documentation is not only a formality. It is the main evidence that your related-party pricing is arm’s length. Without it, the business may struggle to defend its tax position if the FTA asks questions.
Weak documentation can be risky too. Generic descriptions, mismatched figures, missing benchmarking or inconsistent agreements can make the position easier to challenge.
ZeroSync prepares transfer pricing documentation for Dubai trading groups, holding companies, service businesses, free zone entities and UAE subsidiaries of multinational groups. The documentation is tailored to the transaction profile rather than copied from a generic template.
| Business type | Documentation focus |
|---|---|
| Trading groups | Goods flows, margins, purchase and sales pricing |
| Service entities | Management fees, cost-plus support and actual service benefit |
| Holding companies | Dividend flows, financing, IP and shareholder support |
| Free zone companies | Arm’s length support connected to QFZP position |
| MNE subsidiaries | Consistency with group Master File and local disclosure |
These links connect this page to live ZeroSync service pages and tools that visitors can use now.
Corporate Tax Services DubaiCorporate Tax AdvisoryCorporate Tax Return FilingQFZP Assessment and FilingUAE Corporate Tax CalculatorCorporate Tax Deadline CheckerBookkeeping Services DubaiFinancial Statement ServicesContact ZeroSyncA complete documentation file is far easier to defend when it is prepared before filing, not after a notice. ZeroSync can scope, benchmark, prepare and maintain your files.
A taxable person generally needs Master File and Local File documentation if revenue is at least AED 200 million in the tax period or it is part of an MNE group with total consolidated group revenue of at least AED 3.15 billion.
It is a schedule filed with the corporate tax return to report related-party and connected-person transactions above the relevant thresholds, including transaction types, values and the transfer pricing method used.
The disclosure form is filed with the return. Master and Local Files must be maintained and provided on request, so best practice is to prepare them contemporaneously rather than after a notice arrives.
Without documentation, you have limited evidence that prices were arm’s length. The FTA can adjust taxable income and apply penalties or interest where the tax position is not supported.
Documentation should be reviewed each tax period because transactions, functions, risks, comparables and financial results change over time.
Yes. ZeroSync can prepare or strengthen documentation for prior periods where needed, although contemporaneous documentation is always stronger for audit defence.
No. The disclosure form is a return schedule. The Master File and Local File are detailed standalone documents required only where the taxpayer crosses the size thresholds.
Corporate tax records and supporting transfer-pricing files should be retained for the required UAE tax record-retention period so they can be produced if requested by the FTA.
