Service · Tax · UAE Corporate Tax related parties

Transfer pricing for UK-UAE groups, arm's length and audit-ready.

Disclosure forms, Local Files, Master Files, benchmarking studies. If your UAE entity transacts with related parties anywhere, UAE Corporate Tax now requires the documentation. We prepare it before FTA asks for it.

From AED 8,000 per file (≈ £1,720) OECD-aligned methodology 30-day turnaround

UAE TP thresholds

What you owe FTA, by entity size

Disclosure form (all entities)Always

Required with every CT return if any related-party transactions

Local FileRevenue ≥ AED 200m

Or if part of group with consolidated revenue ≥ AED 3.15bn

Master FileGroup ≥ AED 3.15bn

Group-level transfer pricing policy document

Country-by-Country ReportGroup ≥ AED 3.15bn

Multinational groups, headquartered or HQ-substituted in UAE

Source: Ministerial Decision 97 of 2023 + Ministerial Decision 114 of 2023. Penalties for non-compliance start AED 20,000 per missing document.

When this matters

Three founder scenarios where TP becomes urgent.

Most founders only discover transfer pricing exists when their first UAE CT return is due. By then the policy choices that affect the disclosure form have already been made. Three common patterns we see.

Scenario 1, UK Ltd + UAE FZE selling globally

Your UK Ltd provides services to global clients. UAE FZE invoices the end client and pays UK Ltd a service fee. FTA will ask: is the service fee arm's length?

End-client invoice (issued by UAE FZE)AED 1,000,000

Service fee paid to UK LtdAED 900,000

UAE FZE profit margin10%

FTA test, benchmarking required to defend 10%Local File needed if AED 200m+

Scenario 2, founder royalty or management fee from UAE to UK

UAE entity pays a royalty for IP, or a management fee, to UK Ltd owned by the same shareholder. FTA scrutiny is highest on these because they shift profit out of UAE 9% to UK 25%.

UAE FZE revenueAED 5,000,000

Royalty paid to UK LtdAED 2,000,000

UAE taxable profit (after royalty)AED 500,000

If FTA disallows half the royalty, taxable profitAED 1,500,000 (+AED 90k tax)

Deliverables

Each transfer pricing file, built to FTA standard.

We follow the OECD TP Guidelines and Ministerial Decisions 97/114 of 2023. Every file we deliver is one you can hand straight to FTA in an audit. No template-fill work.

Functional and risk analysis

Who does what in the group, who bears which risk, who holds which IP. The foundation that determines which TP method applies. 4-6 hours of founder interviews plus documentation.

Benchmarking study

Comparable companies from RoyaltyStat, Orbis, or Bloomberg databases. We license one for the duration of the engagement. The arm's length range is defended by data, not assertion.

Local File preparation

The UAE-specific document FTA will request. Entity description, controlled transactions, financial information, TP method selection, benchmarking results. 40-60 pages typically.

Master File (where required)

Group-level document showing overall TP policy, intangibles, financing structures, financial activities. Same document used across all jurisdictions, prepared once for the group.

Disclosure form completion

The TP disclosure form filed alongside the UAE CT return. Lists every controlled transaction by counterparty and category. We complete it for you within the CT engagement.

Year-end policy review

Once the file is built, it needs an annual refresh as the business evolves. New transactions, new IP, new entities. We review yearly and update only what changed.

Pricing

Project pricing, by deliverable.

Transfer pricing is not a monthly retainer for most clients, it is annual file preparation. Pricing below covers the file. Year two refreshes are 40% of year one.

Disclosure only

Simple structure · 1-3 transactions

AED 8,000one-off (≈ £1,720)

Annual refresh AED 3,500 (≈ £753)

Disclosure form completion
Functional analysis memo
Method selection rationale
Filed with your CT return

Start engagement

Local File

Revenue AED 200m+ · benchmarking included

AED 18,000one-off (≈ £3,870)

Annual refresh AED 7,500 (≈ £1,613)

Disclosure form
Full Local File (40-60 pages)
Benchmarking study (database access)
Functional and risk analysis
FTA query response support

Start engagement

Master File + CbCR

Group ≥ AED 3.15bn · multi-jurisdiction

From AED 35,000one-off (≈ £7,525)

Quoted after scoping call

Everything in Local File
Master File preparation
Country-by-Country Report
Multi-jurisdiction filings
Group policy advisory

Request quote

Custom plan

Not in a standard tier? Build your own.

Scopedper engagement

If you face a TP controversy, run a complex group, or need an APA, we scope a custom engagement to the specific facts and timeline.

Advance Pricing Agreement (APA) support
Multi-jurisdiction TP files (UK + UAE + EU + US)
Controversy support (FTA query response, MAP)
BEPS Pillar Two (15% global minimum tax) analysis

Talk to a partner

Common questions

Transfer pricing questions founders ask first.

Do I need transfer pricing if my UAE entity is in Free Zone with 0% CT?

Yes. The 0% Qualifying Free Zone Person status itself requires arm's length pricing on related-party transactions. If you fail the TP test, you lose QFZP status and the 0% rate becomes 9% on all qualifying income. The disclosure form is mandatory regardless of rate.

What if my only related-party transaction is paying myself a salary?

Director's remuneration falls inside scope. We document that the salary is at market rate for the role, location, and experience. Usually a 2-3 page memo, included in the disclosure-only engagement. Saves you from a "the founder shifted profit out via salary" challenge later.

How does FTA actually audit transfer pricing?

FTA opens a TP review with a formal request for the Local File and supporting workings. You have 30 days to respond. If they disagree with your method, they propose an adjustment. You can accept it, or appeal. Better outcome: document well at filing time so the review never opens.

Can you do TP for UK side too?

UK has its own TP regime under TIOPA 2010. Different rules, similar logic. Most of our clients consolidate the UK TP work with us so the methodology aligns across jurisdictions. We use the same data, two documents.

What is the OECD method selection?

Five OECD-approved methods: CUP (comparable uncontrolled price), Resale Price, Cost Plus, TNMM (transactional net margin), Profit Split. We pick the one that fits your facts and defend the choice in the Local File. Most services groups use TNMM. Most distribution groups use Resale Price.

How long does this take to deliver?

Disclosure-only: 14 days. Local File: 30 days. Master File: 45-60 days. Year two refreshes are 14 days regardless of complexity. The constraint is usually how fast you give us the financial data and answer the functional interview questions.