- home
- Services
- International Tax & Transfer Pricing (UAE)
International Tax & Transfer Pricing (UAE) — Strategy, Compliance & Support
Clear policies, clean documentation, and audit/MAP support.
International Tax & Transfer Pricing — Strategy, Compliance & Support
We align your cross-border model to UAE Corporate Tax, OECD-style transfer pricing, and treaty rules—covering documentation, benchmarking, intercompany policies, and audits/MAP.
What We Cover
• Transfer Pricing (TP) policy & benchmarking (CUP, TNMM, RPM, Cost-Plus, Profit Split), tested against UAE’s arm’s-length principle aligned with OECD guidance. (FTA UAE)
• Intercompany agreements — drafting, pricing mechanics, KPIs, and governance.
• Master File & Local File — scoping, preparation, and annual refresh where required. (FTA UAE)
• TP disclosure form — preparation and filing alongside the Corporate Tax return. (FTA UAE)
• Country-by-Country Reporting (CbCR) — notifications/filings for UAE-headquartered MNEs. (UAE Ministry of Finance)
• Permanent Establishment (PE) & Nexus — risk assessments for non-residents; construction/service PEs; natural-person presence rules. (UAE Ministry of Finance, FTA UAE)
• Double Tax Treaties (DTTs) — treaty relief, withholding tax analysis, tie-breaker residency, and MAP support. (UAE Ministry of Finance)
• Pillar Two / 15% DMTT (large MNEs) — scoping, data readiness, and top-up tax impact from FYs starting 1 Jan 2025. (UAE Ministry of Finance, PwC)
• Dispute prevention & Support — audit support, MAP requests; APA readiness as the UAE framework rolls out (unilateral APAs expected from Q4 2025). (UAE Ministry of Finance, Grant Thornton UAE)
UAE Transfer Pricing at a Glance
• Arm’s-length principle applies to related party / connected person dealings; UAE follows OECD-style methods and comparability analysis. (FTA UAE)
• Documentation thresholds (Master & Local File):
o Part of an MNE Group with consolidated revenue ≥ AED 3.15bn, or
o Your UAE entity revenue ≥ AED 200m in the period.
• TP disclosure form is filed with the Corporate Tax return (within 9 months of period end). (FTA UAE)
• CbCR: applies to UAE-headquartered MNEs meeting the AED 3.15bn threshold; notification/reporting via MoF. (UAE Ministry of Finance)
Quick facts — UAE TP & International Tax
• Who needs TP files? Prepare Master File + Local File if UAE revenue is AED 200m+ or the group’s global revenue is AED 3.15bn+.
• Disclosure with the CT return: File the Related-Party/Controlled Transactions disclosure together with the CT return.
• CbCR: Only for UAE-HQ groups with global revenue AED 3.15bn+.
• 15% “Pillar Two” (DMTT): For very large MNE groups (global revenue EUR 750m+) starting FYs on/after 1 Jan 2025.
• APAs: As UAE options open, we prepare clients to be APA-ready.
Our Process (UAE-Compliant)
1. Scoping & Risk Map — related parties, connected persons, PE/treaty footprint, Pillar Two exposure. (FTA UAE, UAE Ministry of Finance)
2. Functional & Economic Analysis — value chain, FAR (functions, assets, risks), method selection and benchmarking. (FTA UAE)
3. Policy & Contracting — draft intercompany agreements, pricing mechanics, service catalogues, and KPIs.
4. Files & Forms — Master/Local File, TP disclosure form; CbCR notification/report if in scope. (FTA UAE, UAE Ministry of Finance)
5. Implementation & Controls — ERP tax codes, tested margins, true-ups, and governance calendar.
6. Support-Ready — audit packs, MAP strategy; APA pre-work where helpful. (UAE Ministry of Finance, Grant Thornton UAE)
Deliverables You Receive
• Transfer Pricing Policy (+ benchmarking set)
• Intercompany Agreements (services, distribution, financing, IP)
• Master File & Local File (where thresholds met)
• TP Disclosure Form (with CT return) (FTA UAE)
• PE/Nexus Opinion and treaty relief memo (UAE Ministry of Finance)
• Support Pack (audit responses, reconciliations, evidence) + MAP/APA path where suitable (UAE Ministry of Finance, Grant Thornton UAE)
Controls (Cross-Border)
• Permanent Establishment Checks We Put in Place: onsite days, construction/service duration tests, decision-maker locations. (UAE Ministry of Finance, FTA UAE)
• Free Zone & Mainland interactions: pricing and substance to preserve incentives where applicable.
• Financing & cash pools: interest rates, thin-cap style tests through arm’s-length pricing. (FTA UAE)
• Intangibles & DEMPE: IP ownership vs. development/management functions (documentation trails). (FTA UAE)
• Pillar Two readiness: entity scoping, data model, ETR/top-up simulations; UAE DMTT from FY 2025. (UAE Ministry of Finance, PwC)
Common Mistakes & Audit Triggers
- Group org chart; consolidated and local financials
- Intercompany agreements, pricing policies, and SOPs
- Trial balance, segment P&Ls, management accounts
- Benchmarking comps (if any), prior TP/valuation reports
- Headcount by function; R&D/IP registers; treasury terms
- Project logs / travel calendars (for PE analysis)
Common Mistakes & FTA Red Flags
- No TP disclosure form or incomplete related-party listings. (FTA UAE)
- Missing Master/Local File when thresholds are met; outdated benchmarks.
- Intercompany services with weak evidence of benefit or duplication. (FTA UAE)
- Under-documented PE risk from in-country project teams / decision makers. (UAE Ministry of Finance)
- CbCR notification/report gaps for UAE-headquartered groups. (UAE Ministry of Finance)
Call-to-Action
Let’s make your cross-border model bulletproof.
We’ll design your TP policy, prepare files/forms, and defend outcomes under audit, MAP—or APA when available.
Frequently Asked Questions
Yes—if your UAE entity’s revenue ≥ AED 200m, or your group meets the AED 3.15bn MNE threshold. Otherwise, keep proportionate TP support and the disclosure form (if materiality is met).
With the Corporate Tax return—within 9 months of the end of your tax period. (FTA UAE)
You may seek a corresponding adjustment via treaty MAP to relieve double taxation. We prepare the case file and liaise per the new MoF MAP guidance (June 2025). (FTA UAE, UAE Ministry of Finance)
UAE-headquartered MNEs with consolidated revenue ≥ AED 3.15bn (notification and reporting per MoF rules). (UAE Ministry of Finance)
The FTA is rolling out an APA framework; unilateral APA applications are expected from Q4 2025 (timelines/procedures per FTA decisions). Until then, we focus on strong documentation and MAP where needed. (Grant Thornton UAE)
Large MNEs may face a 15% Domestic Minimum Top-up Tax (DMTT) in the UAE for FYs starting 1 Jan 2025; we assess scope and model top-up exposures. (PwC, UAE Ministry of Finance)
Get in touch
