Transfer Pricing Services

OECD-Compliant Documentation & Benchmarking

The implementation of Corporate Tax in the UAE has made transfer pricing a critical compliance requirement based on OECD principles. At Apex Accounting, we offer comprehensive transfer pricing services including detailed assessments, impact evaluations, and robust documentation. Our experts leverage top benchmarking software to ensure arm’s length pricing for transactions between related parties, safeguarding your tax base and minimizing audit risk. We provide tailored solutions to help you comply with FTA regulations while optimizing your international operations.

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What We Offer

Services Include

Transfer Pricing Policy Development
Benchmarking Studies (Using Global Databases)
Country-by-Country Reporting (CbCR)
Comparability Analysis
Intercompany Agreement Review
GloBE/Pillar Two Compliance Advisory

Is This For You?

Who Needs This Service

Multinational enterprises (MNEs) with UAE entities and related party transactions
Companies with connected person transactions exceeding AED 500,000 annually
Groups with revenue exceeding AED 200 million requiring Local File documentation
MNEs with consolidated revenue over AED 3.15 billion requiring Master File and CbCR
Free Zone companies transacting with mainland related parties
Businesses providing management fees, royalties, or intercompany loans
Companies seeking to minimize transfer pricing audit risk exposure
Organizations restructuring cross-border operations involving UAE entities

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How We Work

Our Process

Step 1

Transaction Mapping & Assessment

We identify all related party transactions (domestic and international), categorize them by type, and assess your transfer pricing exposure under UAE Corporate Tax law and OECD guidelines.

Step 2

Functional Analysis (FAR)

Our experts conduct detailed Functions, Assets, and Risks (FAR) analysis to understand the economic substance and value contribution of each entity in controlled transactions.

Step 3

Benchmarking & Price Testing

Using globally recognized databases (Bureau van Dijk, S&P Capital IQ), we perform comprehensive benchmarking studies to establish arm's length ranges for your intercompany pricing.

Step 4

Documentation & Compliance

We prepare robust transfer pricing documentation including Disclosure Forms, Local Files, Master Files, and CbCR reports that meet FTA requirements and withstand regulatory scrutiny.

Step 5

Ongoing Support & Defense

We provide continuous support for transfer pricing queries, help with voluntary adjustments, and represent your business during FTA transfer pricing audits.

Why Choose Us

Key Benefits

OECD-Aligned Expertise

Our transfer pricing approach follows OECD Transfer Pricing Guidelines, ensuring your documentation meets international best practices adopted by the UAE.

Advanced Benchmarking Tools

We use globally recognized databases and benchmarking software to establish defensible arm's length ranges for all transaction types.

Audit Risk Mitigation

Proper documentation significantly reduces the risk of transfer pricing adjustments and penalties during FTA audits.

Threshold Monitoring

We help you track documentation thresholds (AED 500K, AED 4M, AED 40M, AED 200M) and ensure timely compliance.

Integrated Tax Planning

Transfer pricing strategies aligned with your overall Corporate Tax position and group-wide tax efficiency goals.

Cross-Border Expertise

Deep understanding of how UAE transfer pricing rules interact with regulations in other jurisdictions where your group operates.

Common Questions

Frequently Asked Questions

What transactions require transfer pricing documentation in the UAE?

Any transaction with a 'Related Party' or 'Connected Person' as defined under UAE Corporate Tax law requires arm's length pricing. This includes sales of goods, provision of services, loans, guarantees, use of intangibles, cost sharing arrangements, and management fees.

What are the transfer pricing disclosure thresholds?

Transactions exceeding AED 500,000 with connected persons must be disclosed. If any category exceeds AED 4 million or total related party transactions exceed AED 40 million, additional disclosure requirements apply. Companies with revenue above AED 200 million must maintain a Local File.

When is a Master File and Country-by-Country Report required?

A Master File is required for MNEs with UAE consolidated revenue exceeding AED 200 million. CbCR is mandatory for MNE groups with consolidated revenue exceeding AED 3.15 billion (EUR 750 million equivalent).

What are 'off-financial statement' transactions?

These are transactions that may not appear in your financial statements but still have transfer pricing implications, such as guarantees provided between related parties, collateral arrangements, expenses incurred on behalf of related parties, and secondment of employees.

Can transfer pricing adjustments be made after year-end?

Yes, transfer pricing adjustments can be made before audit, after audit, or during return filing. There is no mandatory requirement to complete adjustments before proceeding with the audit, but early adjustments reduce potential penalty exposure.