Transfer pricing
Our briefings on Transfer pricing in the UAE — practical, current guidance from the FW Global team.
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Who is a Related Party and a Connected Person?
Before you can apply the arm's length rule, you need to know who it catches. UAE Corporate Tax uses two definitions, Related Party and Connected Person. Payments to owners are the blind spot. Here is who is who, and why it matters.
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Transfer pricing in the UAE: the arm's length principle.
Transfer pricing requires related parties to price their dealings as independent parties would. It matters even at a single tax rate, and the Authority can adjust prices that fall short. Here is the principle at the heart of the regime.
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Benchmarking studies: what a defensible one contains.
A benchmarking study is what turns a transfer price from an assertion into a defensible position. A weak one is worse than none. Here is what a defensible study contains, from functional analysis to the arm's length range.
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The transfer pricing documentation set: master file, local file, disclosure.
Transfer pricing is enforced through paperwork: a disclosure everyone files, and master and local files above thresholds. Which tier you sit in decides the whole scope. Here is the documentation set, and who has to keep it.
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Transfer pricing for intercompany financing and loans.
When one group company lends to another, the interest must be arm's length in both rate and rationale, and it still faces the interest limitation on top. A shareholder loan is tested more than once. Here is how to keep it defensible.
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Transfer pricing for management fees and intra-group services.
Management fees and intra-group services are legitimate and heavily scrutinised. The Authority tests them twice: did the service happen, and was the charge arm's length. Here is the benefit test, the shareholder-cost trap, and pricing.
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Choosing a transfer pricing method.
To show a related-party price is arm's length you measure it against something. There are five methods, and the rule is the most appropriate one, not the most convenient. Here is what each does, and when it fits.
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Common transfer pricing mistakes UAE groups make.
Transfer pricing errors repeat. Across UAE groups the same gaps appear: no documentation, round-number fees, ignored connected persons, agreements that do not match reality. Here are the common mistakes, and how to close them.