Intra-Group Services
Most transfer pricing files in the UAE start with a benchmark and work backwards to a story. The Federal Tax Authority reads them in the opposite direction, testing who controls each risk and whether conduct matches contract before the interquartile range gets any attention.
We serve UAE-headquartered groups, regional holding structures, free zone entities, family conglomerates and inbound multinationals across the GCC — from policy design through documentation, benchmarking, APAs and audit defence.
From policy design through documentation, benchmarking, APAs and audit defence.
Group-wide pricing policy, entity characterisation and month-end true-up mechanics your finance team runs, so margins land inside the range before the return is prepared.
Disclosure Form, Local File, Master File and CbCR prepared contemporaneously, reconciled to audited financials and ready for the 30-day Tax Authority request.
TNMM searches on S&P Capital IQ with Orbis independence screening, CUP evidence from RoyaltyStat, ktMINE and property market data, every rejection recorded.
Benefit test, shareholder cost carve-out, allocation keys and mark-up support for management fees and head office charges, the most frequently disallowed item in UAE reviews.
Chapter X delineation, standalone and group-adjusted credit ratings, interest, guarantee and cash pool pricing, and defence memoranda for interest-free shareholder funding.
Function mapping across the group so the return on brands, software and know-how sits with the entities controlling them, with royalty rates tested against residual profit.
QFZP arm’s length compliance, recognised price reporting agencies for commodity traders, and Article 36 market value benchmarks for owner, director and family payments.
Exit charge quantification before execution, options realistically available for both parties, and value chain analysis showing where profit is earned before any entity is priced.
Unilateral APA applications, 30-day documentation responses, technical position papers, Tax Disputes Resolution Committee representation and MAP relief under UAE treaties.
One regional policy with local files for KSA, Qatar, Oman, Bahrain, Kuwait and Egypt, mirror-image India-UAE documentation, and transfer pricing positions tested for QDMTT effect.
| Obligation | Trigger | What the Tax Authority Expects |
|---|---|---|
| Arm's length pricing, Article 34 | Every related party transaction, domestic and cross-border, whatever the entity size | Pricing evidence in place at the time of the return |
| Disclosure Form | Related party transactions above AED 40m in aggregate, categories above AED 4m, connected person payments above AED 500,000 | Figures reconciled to financial statements and the Local File |
| Local File and Master File, MD 97/2023 | Revenue of AED 200m, or group revenue of AED 3.15bn | Production within 30 days of request, seven-year retention |
| Country-by-Country Report | Group revenue of AED 3.15bn or more | Filing within 12 months of year end, consistent with the Master File |
| Connected persons, Article 36 | Payments to owners, directors and their relatives | Deduction limited to market value |
| Qualifying Free Zone Person | Every free zone related party transaction | Arm's length compliance as a qualifying condition. Failure ends the 0% regime for five tax periods |
| Unilateral APA | Covered transactions of AED 100m or more per tax period | Three to five years of agreed pricing with the Tax Authority |
Partner-led work at a cost and speed
Our FAR-C Control Matrix characterises each transaction from decision-making evidence before any benchmark runs.
S&P Capital IQ, RoyaltyStat, ktMINE and Orbis, reproducible by the FTA or a foreign authority.
Corporate tax, QFZP status, VAT, ESR, e-invoicing through Marmin and QDMTT handled within one group.
Published in the IBFD International Transfer Pricing Journal and Tax Notes International, Kaplan MENA’s educator for the UAE Transfer Pricing Diploma, contributor to OECD public consultations.
Offices in Dubai, Abu Dhabi, Riyadh, Kuwait City, Muscat, Doha, Manama and Jaipur. Local files prepared where the entity sits.
Answers to the questions we hear most often from UAE and GCC groups.
Every related party transaction, domestic and cross-border, must meet arm’s length pricing under Article 34, whatever the entity size. The size of your transactions and group revenue then determines which additional documentation obligations apply.
The Disclosure Form applies once related party transactions exceed AED 40m in aggregate, individual categories exceed AED 4m, or connected person payments exceed AED 500,000. Figures must reconcile to the financial statements and the Local File.
Under Ministerial Decision 97/2023, a Local File and Master File are required once revenue reaches AED 200m, or group revenue reaches AED 3.15bn. Both must be produced within 30 days of an FTA request, with seven-year retention.
Yes, if group revenue is AED 3.15bn or more. The CbCR must be filed within 12 months of year end and stay consistent with the Master File.
Under Article 36, connected person payments are deductible only up to market value, so these payments need the same arm’s length support as any related party transaction.
Arm’s length compliance is a qualifying condition for Qualifying Free Zone Person status. Failure ends the 0% corporate tax regime for five tax periods.
Yes. Unilateral APA applications are available for covered transactions of AED 100m or more per tax period, securing three to five years of agreed pricing with the FTA.
We run TNMM searches on S&P Capital IQ with Orbis independence screening, and use CUP evidence from RoyaltyStat, ktMINE and property market data, with every rejection recorded so searches are reproducible by the FTA or a foreign authority.
We build the benefit test, shareholder cost carve-out, allocation keys and mark-up support for these charges, the most frequently disallowed item in UAE reviews, so the documentation is built to withstand scrutiny.
Yes. We prepare one regional policy with local files for KSA, Qatar, Oman, Bahrain, Kuwait and Egypt, plus mirror-image India-UAE documentation, and test positions for QDMTT and Pillar Two effect.
Partner and Head of Transfer Pricing
