If your company deals with a parent, subsidiary, sister company, shareholder, director or connected owner, UAE corporate tax expects those transactions to follow the arm's length principle. ZeroSync Accountants helps Dubai businesses review, document and defend related-party pricing before the FTA asks questions.
Best for mainland companies, free zone entities, trading groups, holding structures, service companies and businesses with connected-person payments.
Transfer pricing is the pricing framework for transactions between related parties and connected persons. Under UAE corporate tax, these dealings must be priced as if independent parties had agreed the same terms in comparable circumstances. This is known as the arm's length principle.
The rules can cover cross-border transactions, domestic UAE transactions, mainland to free zone arrangements, group service fees, shareholder payments, director fees, rent paid to connected persons, royalties, financing and cost recharges.
Transfer pricing is not just a large multinational issue. A Dubai SME can also have controlled transactions if the business deals with owners, directors, relatives or group companies. Weak pricing support can affect corporate tax filings, QFZP status, accounting records and FTA review readiness.
Every taxable person with related-party or connected-person transactions should consider whether the transaction is at arm's length. The level of documentation depends on the taxpayer profile, transaction type and threshold position.
| Business situation | Likely TP requirement | How ZeroSync helps |
|---|---|---|
| Any UAE business with related-party or connected-person dealings | Arm's length pricing and practical support for the position | Related-party mapping, pricing review and evidence file |
| Taxable person with reportable controlled transactions | Transfer pricing disclosure form with the corporate tax return, where applicable | Disclosure review, transaction classification and filing support |
| Revenue of AED 200 million or more in the tax period | Master File and Local File may be required | Contemporaneous TP documentation, benchmarking and functional analysis |
| Member of an MNE group with consolidated revenue of AED 3.15 billion or more | Master File and Local File may be required | Group documentation alignment and UAE local file support |
| UAE headquartered MNE group above the CbCR threshold | Country-by-Country Reporting obligations may apply | CbCR notification and filing support where in scope |
Not every business needs a full Master File and Local File. Our first step is to confirm what is actually required so you do not over-document or under-document your UAE transfer pricing position.
We map related parties, connected persons, transaction types, values and tax impact so you know whether TP rules apply and what action is needed.
We test margins, fees, interest, royalties and service charges against suitable comparables and document the search approach.
We prepare UAE transfer pricing documentation with group overview, functional analysis, method selection, transaction details and financial support.
We review transaction thresholds, prepare the disclosure schedule and align the form with accounts and corporate tax return data.
We help draft or review agreements for services, loans, royalties, cost sharing, management fees and group recharges.
We prepare technical responses, evidence packs and supporting analysis if your transfer pricing position is reviewed by the FTA.
A short scoping call can separate real obligations from unnecessary paperwork. We review your structure, related-party transactions and corporate tax filing position.
This section targets practical search intent around related-party transactions, connected persons, intercompany agreements and FTA review triggers.
Choosing the right method is central to a defensible file. We do not force every transaction into one method. We look at the facts, functions, assets, risks and available comparables before choosing the best method.
Our benchmarking and documentation work explains what each party does, what risks it controls, what assets it uses, which method was selected, what comparables support the result and why the final price is arm's length.
| Common transaction | Typical method | What we evidence |
|---|---|---|
| Sale of goods to a sister company | Comparable uncontrolled price or cost plus | Margin matches independent dealings and commercial terms |
| Intra-group services and management fees | Cost plus or transactional net margin method | Service is real, beneficial and fairly charged |
| Financing between group members | Comparable uncontrolled price | Interest and terms reflect market pricing |
| Use of IP, software, brand or know-how | Comparable uncontrolled price or profit split | Royalty or allocation reflects arm's length value |
We identify related-party and connected-person transactions and confirm the likely documentation tier.
We document the functions performed, assets used and risks assumed by each party.
We test pricing against independent comparables and quantify any required adjustment.
We prepare the disclosure form, evidence file, Master File or Local File where required.
We align intercompany agreements with the actual pricing model and accounting treatment.
We keep your file current and help respond if the FTA asks questions.
We support trading firms, holding companies, service businesses, real estate groups, ecommerce companies, logistics companies, consultants and free zone entities across Dubai. This includes businesses in DMCC, JAFZA, DIFC, Dubai Silicon Oasis, Business Bay, Downtown Dubai, JLT, Dubai Marina, Deira, Al Quoz and other UAE business districts.
Free zone status can make transfer pricing more important. A Qualifying Free Zone Person should ensure related-party pricing is supportable, especially where mainland income, group recharges, royalties, financing or service fees are involved.
We can review free zone income streams, related-party transactions, intercompany agreements and accounting records together with your QFZP position.
| Term | Meaning in practice | Examples |
|---|---|---|
| Related parties | Persons linked through ownership, control, common control or qualifying family relationships. | Parent and subsidiary, sister companies, entities controlled by the same owner. |
| Connected persons | Owners, directors, officers and certain relatives or related entities receiving payments or benefits from the business. | Owner salary, director fee, rent paid to a shareholder, payment to a director's relative. |
| Controlled transactions | Transactions or arrangements between related parties or connected persons that must be tested against arm's length outcomes. | Sales, loans, services, royalties, guarantees, cost allocations and management fees. |
Global TP methodology delivered in a practical way for Dubai SMEs, groups and growing businesses.
We help you prepare what you need, not a heavy file that adds cost without value.
Our TP support connects with bookkeeping, financial statements, corporate tax filing and FTA readiness.
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Corporate Tax Services Dubai Corporate Tax Registration Corporate Tax Return Filing Corporate Tax Advisory UAE Corporate Tax Calculator Corporate Tax Deadline Checker QFZP Qualifying Income Checker Small Business Relief CheckerYes. UAE transfer pricing rules can apply to related-party and connected-person transactions whether the parties are in the UAE mainland, a free zone or another jurisdiction. Documentation thresholds depend on the taxpayer size and transaction facts.
A Master File and Local File are generally required where the UAE taxable person's revenue is AED 200 million or more in the tax period, or where it is part of an MNE group with consolidated group revenue of AED 3.15 billion or more.
It is a schedule submitted with the corporate tax return where applicable. It reports controlled transactions, related parties, connected persons, transaction values and the transfer pricing method used to support the arm's length position.
A Qualifying Free Zone Person should keep related-party transactions at arm's length to protect its UAE corporate tax position. Weak support for management fees, royalties, financing or mainland to free zone flows can create risk.
The FTA may adjust taxable income to an arm's length amount. This can increase tax payable and may create penalty or interest exposure. Proper benchmarking and contemporaneous documentation help defend your position.
Yes. We can review the transaction, prepare technical responses, strengthen supporting documentation, build benchmarking evidence and help manage communication during the review.
Documentation should be contemporaneous and reviewed at least annually, especially when revenue, transaction values, business functions, risks, assets, intercompany agreements or market conditions change.
A smaller group may not need full Master File and Local File documentation, but it may still need evidence that related-party pricing is arm's length. A proportionate benchmarking review can support the position without overbuilding the file.
Before your next corporate tax filing, make sure your related-party pricing, connected-person payments and documentation are defensible.
