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Tax

Transfer pricing

Related-party pricing set on a documented basis, supported by benchmarking, and recorded while the reasoning is still fresh.

What it is

Where entities in a group transact with each other, the pricing has to reflect what independent parties would have agreed — and be supported by analysis prepared at the time. Documentation assembled retrospectively is materially weaker than documentation prepared alongside the transaction.

Who it applies to

Who this is for.

  • Groups whose UAE entities transact with entities elsewhere
  • Businesses with intra-group management charges, financing or licensing
  • Trading groups moving goods between related entities
  • Family groups with transactions between commonly owned businesses

What we do

The work itself.

  1. Identify and characterise every category of related-party transaction

  2. Select and justify the appropriate pricing method for each

  3. Prepare benchmarking analysis from comparable data

  4. Prepare the Local File and, where required, the Master File

  5. Review the position as the group and its transactions change

What you provide

What we will need from you.

Gathering these before the first conversation shortens everything that follows.

  • Group structure and ownership chart
  • Intra-group agreements, where they exist
  • Transaction volumes and values by category
  • Functional detail — who does what, and where

Timeline

A documentation engagement typically runs four to eight weeks depending on the number of transaction categories and the availability of functional information.

Rates, thresholds and filing dates change. We confirm the current position for your entity in writing rather than publishing figures that may date.

Questions

What people ask.

It is common and it is fixable. Part of the work is documenting what the arrangement actually is, then putting it on a proper footing going forward.

Next step

Transfer pricing, handled properly.

Tell us where you are with it. If the answer is that you have nothing to do, that is what you will hear.

Not ready for a meeting? Ask one specific question instead.

What follows

  • A person in the relevant practice reads it, not a routing queue.
  • One reply that already contains a view, not a request to book a call.
  • A written scope and fee basis, or a straight answer that there is no work to do.
  • Sunday – Thursday, 9:00 – 18:00 GST