Tasama Management Consultancy

Transfer Pricing

Related-party pricing that stands up to disclosure.

Related-party transaction mapping, master file and local file preparation, benchmarking coordination, policy design and disclosure-form readiness aligned to the arm's length principle and OECD guidance.

Discuss transfer pricing →All services

Key takeaways

  • 01Transfer pricing rules apply to transactions with related parties and connected persons, including cross-border intercompany charges, management fees and financing.
  • 02All in-scope transactions must meet the arm's length principle — priced as they would be between independent parties.
  • 03A master file and local file are required once revenue and transaction-size thresholds are met.
  • 04A transfer pricing disclosure form is filed alongside the Corporate Tax return.

What we deliver

Transfer Pricing services

01

Related-Party Transaction Mapping

Identification of related parties and connected persons and a register of the intercompany flows in scope.

02

Master File & Local File

Preparation of OECD-aligned documentation covering the group, the local entity and its controlled transactions.

03

Benchmarking Coordination

Coordination of comparable searches and economic analysis to support the arm's length position.

04

Transfer Pricing Policy Design

A practical intercompany pricing policy for goods, services, IP and financing that finance can actually apply.

05

Disclosure Form Readiness

Preparation of the data needed for the transfer pricing disclosure form filed with the Corporate Tax return.

Questions

Transfer Pricing, answered

What triggers a transfer pricing requirement?
Any transaction with a related party or connected person — including cross-border intercompany charges, shareholder or management fees, and intra-group financing — brings the arm's length principle and disclosure obligations into play under the UAE Corporate Tax law.
Do I need both a master file and a local file?
Full master file and local file documentation is required once the relevant revenue and transaction thresholds are met. Below those levels, businesses still need to price related-party dealings at arm's length and support the position, but the formal file set may not be mandatory.
What is the arm's length principle?
It requires related parties to price transactions between them as unrelated parties would in comparable circumstances. Where they do not, taxable profit is adjusted to the arm's length outcome.

Let’s talk

Ready to discuss a serious advisory mandate?

Tell us where your business is heading. We will help identify the tax, finance, compliance and strategy support required to move with confidence.

Request advisory discussion →WhatsApp Tasama