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Transfer Pricing & International

Taxation That Empowers You

Cross-border operations bring opportunity and complexity.

We make sure international transactions are structured, priced, and reported in ways that satisfy regulators and strengthen your global strategy.

Making Global Rules Work for You

Transfer pricing isn’t just an accounting exercise; it’s about building structures that withstand regulatory review while supporting business goals. Our focus is on:

Why Transfer Pricing & International Taxation Matter

Our Transfer Pricing & International Tax Services

Strategic International
Tax Advisory

Make taxation part of your growth strategy.
Repatriation planning and profit allocation Advisory on new global tax initiatives (BEPS 2.0, Pillar Two, etc.)

Cross-Border
Structuring

Design tax-efficient frameworks for global operations.
Double tax treaty analysis
Structuring for inbound/outbound investments

Risk & Dispute
Management

Mitigate disputes before they escalate.

Audit support and regulator communication Advance pricing agreements and dispute resolution

Transfer Pricing Documentation & Benchmarking

Prepare robust, audit-ready files that align with OECD standards and UAE rules. Comparable analysis to defend intercompany transactions Local and master file preparation for multi-jurisdictional businesses

International tax can be
a roadblock or a runway.

With the right partner, it powers smarter structures, stronger
compliance, and seamless cross-border growth.

The choice is yours. We make it simple.

Many think International
tax is technical.

The stakes are higher when borders, regulators, and reputations are all involved. 
Here’s how we make sure you’re on the right side of that equation:

Reviews

Stories From Our Partners

Transfer Pricing & International Taxation
Frequently Asked Questions

Yes. Transfer pricing requirements extend to both cross-border and domestic transactions between related parties. All such transactions must comply with the arm’s length principle.

The Disclosure Form provides the Federal Tax Authority (FTA) with a summary of related-party transactions. It must be filed alongside the corporate tax return when applicable thresholds are met.

The definition is broad and includes entities or individuals connected through ownership, control, or family relationships. This may encompass parent companies, subsidiaries, shareholders, directors, and related family members.

Businesses are required to support their pricing policies with appropriate benchmarking studies and analyses based on comparable transactions between independent parties. Estimates or unsupported assumptions are not sufficient.

Depending on the size and nature of the business, documentation may include:

  • A Master File, outlining the global group’s structure and policies.
  • A Local File, detailing UAE-specific related-party transactions.
  • A Country-by-Country Report (CbCR), required if consolidated group revenues exceed AED 3.15 billion.


Such documentation must be maintained and made available to the FTA within 30 days of request.

The UAE applies the five internationally recognized methods under the OECD Guidelines: Comparable Uncontrolled Price (CUP), Resale Price Method (RPM), Cost-Plus Method, Transactional Net Margin Method (TNMM), and Profit Split Method. Alternative methods may be used only if justified.

Documentation must be retained in a complete and accessible form for the statutory retention period, and must be provided to the FTA within 30 days if requested.

Failure to comply may result in adjustments to taxable income, denial of deductions, financial penalties, and increased audit scrutiny.

Yes. Free Zone entities are subject to the arm’s length principle and related documentation requirements if they engage in transactions with related parties, regardless of the tax incentives they may enjoy.

The UAE’s transfer pricing regime is aligned with the OECD Transfer Pricing Guidelines, adapted to reflect local regulatory and economic considerations.