Transfer Pricing Services in UAE

Managing Related Party Transactions with Confidence

Key Highlights: FTA Approved Partner | GCC Regulatory Compliant | IFRS Standard Audits

The introduction of UAE Corporate Tax has brought increased focus on related party transactions and transfer pricing compliance. Businesses operating within group structures, family-owned groups, multinational organizations, and entities with related party dealings are now required to ensure that transactions are conducted on arm's length terms and supported by appropriate documentation.

At NRS Fynser, we provide practical Transfer Pricing Services designed to help businesses comply with UAE Corporate Tax requirements while managing tax risks and maintaining defensible transfer pricing positions.

Our team assists businesses in assessing related party transactions, developing transfer pricing policies, preparing documentation, and supporting compliance obligations under UAE Corporate Tax regulations and OECD Transfer Pricing Guidelines.

Arm’s length pricing reviews, local file & master file documentation, and compliance advisory.

What is Transfer Pricing?

  • Transfer Pricing refers to the pricing of transactions between related parties, including transactions between group companies, shareholders, directors, branches, and other connected persons.
  • Examples include:
  • Management service charges
  • Intercompany loans and financing arrangements
  • Shared service arrangements
  • Royalty and licensing transactions
  • Sale and purchase of goods between related entities
  • Cost allocation arrangements
  • Director and shareholder remuneration
  • Tax authorities require these transactions to be conducted on an arm's length basis, meaning the pricing should be comparable to what independent parties would agree under similar circumstances.

Our Transfer Pricing Services Include

  • Transfer pricing risk assessments
  • Related party transaction reviews
  • Arm's length pricing analysis
  • Benchmarking studies
  • Transfer pricing policy development
  • Local File preparation
  • Master File preparation
  • Connected Person transaction reviews
  • Transfer pricing documentation support
  • Transfer pricing health checks
  • Support during tax audits and assessments

Transfer Pricing Under UAE Corporate Tax

  • The UAE Corporate Tax regime requires businesses to comply with transfer pricing rules based on internationally recognized OECD principles.
  • Businesses may be required to:
  • Identify related party transactions
  • Assess compliance with the arm's length principle
  • Maintain appropriate documentation
  • Complete transfer pricing disclosures
  • Prepare Local File and Master File documentation where applicable
  • Failure to maintain appropriate transfer pricing support may increase tax risks and exposure during tax reviews or assessments.

Related Party & Connected Person Transactions

  • Many businesses are unaware that transfer pricing rules extend beyond multinational groups.
  • Transfer pricing considerations may apply to transactions involving:
  • Parent and subsidiary companies
  • Group entities
  • Shareholders
  • Directors
  • Family-owned businesses
  • Connected persons
  • Related investment entities
  • We help businesses identify relevant transactions and assess compliance requirements before potential issues arise.

Local File & Master File Documentation

  • Businesses meeting prescribed thresholds may be required to maintain transfer pricing documentation.
  • **Local File**
  • Provides detailed information relating to specific related party transactions undertaken by the UAE entity.
  • **Master File**
  • Provides information relating to the broader group structure, business activities, transfer pricing policies, and intercompany arrangements.
  • Our team assists businesses in preparing documentation that is practical, compliant, and aligned with regulatory expectations.

Benchmarking Studies

  • A benchmarking study helps determine whether related party transactions are consistent with market conditions and arm's length pricing principles.
  • We perform benchmarking exercises to support:
  • Management service charges
  • Intercompany financing arrangements
  • Distribution activities
  • Procurement activities
  • Shared service arrangements
  • Other related party transactions
  • Connected persons’ payments
  • These studies provide objective support for transfer pricing positions adopted by businesses.

Benefits of Professional Transfer Pricing Support

  • **Reduce Tax Risk**
  • Identify and address transfer pricing exposures before they become regulatory concerns.
  • **Strengthen Compliance**
  • Meet documentation and disclosure requirements under UAE Corporate Tax regulations.
  • **Defend Transfer Pricing Positions**
  • Maintain appropriate support for related party transactions and pricing methodologies.
  • **Improve Tax Governance**
  • Establish clear policies and documentation frameworks for ongoing compliance.
  • **Enhance Audit Readiness**
  • Prepare businesses for future tax reviews, assessments, and regulatory scrutiny.

Who We Serve

  • Family-owned business groups
  • UAE corporate groups
  • Free Zone entities
  • Multinational organizations
  • Investment and holding companies
  • Trading and distribution businesses
  • Manufacturing businesses
  • Professional service groups

Why Choose NRS Fynser?

  • Transfer pricing compliance requires a combination of tax expertise, commercial understanding, and practical business knowledge.
  • Our team helps businesses understand the real-world implications of transfer pricing regulations and develop solutions that are commercially practical while meeting regulatory expectations.
  • Businesses choose NRS Fynser for:
  • Strong expertise in UAE Corporate Tax and Transfer Pricing
  • Practical understanding of related party transactions
  • Experience supporting family groups and corporate structures
  • Commercially focused advisory approach
  • Integrated expertise across tax, audit, accounting, and advisory services
  • Commitment to technical excellence and regulatory compliance

Speak to Our Transfer Pricing Specialists

  • Whether you require transfer pricing advisory, benchmarking studies, Local File preparation, Master File documentation, or support in reviewing related party transactions, our specialists can help your business manage compliance and reduce tax risk.
  • Contact NRS Fynser today to discuss your Transfer Pricing requirements.

Frequently Asked Questions

What are related party transactions?

Related party transactions are transactions between entities or individuals that have a relationship through ownership, control, management, or family connections.

Is Transfer Pricing only applicable to multinational companies?

No. Transfer pricing rules may also apply to UAE business groups, family-owned businesses, holding structures, and transactions involving connected persons.

What is the purpose of a benchmarking study?

A benchmarking study helps determine whether the pricing of related party transactions is consistent with market conditions and the arm's length principle.