Transfer Pricing Documentation
Transfer Pricing Documentation Services in UAE
With the introduction of Corporate Tax in the UAE under Federal Decree-Law No. 47 of 2022, businesses are now required to comply with globally aligned Transfer Pricing (TP) rules. These rules are designed to ensure that all transactions between related parties and connected persons are conducted at arm’s length—just as if the parties were independent.
At Accruon Auditing LLC, we provide specialized services in Transfer Pricing Documentation, helping businesses comply with the UAE Corporate Tax Law, Ministerial Decisions, and OECD standards.
Transfer Pricing Under UAE Corporate Tax Law
The key legal references for Transfer Pricing in the UAE are:
- Article 34 – Arm’s Length Principle: All transactions with related parties or connected persons must be priced as if they were between independent parties.
- Article 35 – Related Party Transactions & Connected Persons: Defines scope and conditions for transactions that fall under TP rules.
- Article 55 – Disclosure & Documentation: Requires entities to file transfer pricing disclosure forms and, where applicable, maintain Local File and Master File.
Additionally, the Ministerial Decision No. 97 of 2023 provides detailed guidance on thresholds, documentation, and exemptions.
Who Must Maintain Transfer Pricing Documentation in UAE?
Not every business is required to prepare a Local File or Master File, but every taxable person must comply with the arm’s length principle and, where applicable, complete the TP Disclosure Form with the corporate tax return.
A Local File and/or Master File must be maintained if:
- The business is part of a multinational group with consolidated revenues of AED 3.15 billion or more (aligned with Country-by-Country Reporting thresholds).
- The UAE entity’s revenue, or related party transactions, cross ministerial thresholds as prescribed by the FTA.
- The FTA issues a specific request for documentation, even if below the thresholds.
In short: Large groups and businesses with significant related party transactions are required to maintain detailed TP documentation.
Types of Transfer Pricing Documentation in UAE
1. Transfer Pricing Disclosure Form
- Filed together with the annual corporate tax return.
- Summarizes the nature, volume, and value of related party transactions.
2. Local File (Entity-Level Documentation)
- Contains detailed records of the UAE entity’s related party transactions.
- Must include:
- Description of business activities.
- Functional, asset, and risk (FAR) analysis.
- Benchmarking studies to prove arm’s length pricing.
- Detailed financials linked to the transactions.
3. Master File (Group-Level Documentation)
- Required for large multinational groups.
- Must provide:
- Organizational structure and global operations overview.
- Group’s overall transfer pricing policies.
- Consolidated financial statements and allocation of income.
Our Transfer Pricing Documentation Services
At Accruon Auditing LLC, we provide full-service support to ensure compliance with UAE CT law:
- TP Compliance Review – Assess related party and connected person transactions.
- Preparation of Disclosure Forms – Filing TP forms with the corporate tax return.
- Local File Preparation – Documentation of UAE transactions, FAR analysis, and benchmarking.
- Master File Support – Assistance for groups required to maintain global TP documentation.
- Benchmarking Studies – Justify arm’s length pricing with market-based comparisons.
- FTA Audit Assistance – Support during inspections, queries, and disputes.
Why Transfer Pricing Compliance Matters
- Mandatory under UAE CT Law Articles 34, 35 & 55.
- Avoids FTA penalties and reassessments.
- Provides legal protection during tax audits.
- Aligns your business with international best practices.
- Strengthens investor and regulator confidence.
Why Choose Accruon Auditing LLC?
- Government-recognized audit firm in UAE with authority to conduct audits.
- Expertise in UAE Corporate Tax & Transfer Pricing rules.
- Customized TP documentation tailored to your industry and transactions.
- Proven track record in helping free zone and mainland companies stay compliant.
Stay Compliant with UAE Transfer Pricing Laws
Transfer Pricing is a core focus of the UAE Corporate Tax regime. With professional guidance from Accruon Auditing LLC, your business will have compliant TP Disclosure Forms, Local Files, and Master Files, ready for FTA review.
Contact us today to discuss your Transfer Pricing Documentation requirements in UAE.