Our Core Services

Transfer Pricing Compliance & Economic Advisory

Benchmarking and Economic Analysis

We benchmark your related-party transactions against comparable arm's-length data. This covers intercompany loans, management fees, owner remuneration and goods or service pricing between group entities.

FinApt experience:

benchmarking delivered for owner remuneration, intercompany loans, JAFZA-based goods trading, and DMCC IT management service fees.

Transfer Pricing Compliance and Documentation

Preparation of the documentation the FTA expects to see, sized to your group's scale.

  • Master File preparation
  • Local File preparation
  • Country-by-Country Reporting (CbCR), for groups that meet the threshold
  • Disclosure form support alongside your corporate tax return
Statutory Thresholds: Master File and Local File apply where your business is part of a multinational group with consolidated revenue of AED 3.15 billion or more, or where your own revenue reaches AED 200 million in the tax period. CbCR applies at the AED 3.15 billion consolidated group level.

Transfer Pricing Policy and Advisory

Setting a defensible, workable pricing policy for intercompany transactions before disputes arise. This covers financing arrangements, service charges, and goods pricing between related entities.

Related Party and Connected Person Reviews

A review of your related-party and connected-person transactions to confirm they are correctly identified, priced and disclosed. This includes reviews for connected-person payments made to owners, directors or related entities.

FinApt experience:

connected-person transaction reviews as part of broader transfer pricing engagements.

Transfer Pricing Health Checks and Risk Assessment

A structured review of your existing transfer pricing position. We look at documentation, policies and pricing outcomes to flag gaps before an FTA review does.

Why This Matters for Corporate Tax

Transfer pricing compliance is one of the conditions a Qualifying Free Zone Person must meet to keep the 0% rate on qualifying income. It also connects to your wider corporate tax position and, for larger groups, to Pillar Two reporting. See our corporate tax services and international tax advisory.

Corporate Tax Services → International Tax →
Why FinApt Group

Why FinApt Group for Transfer Pricing

Transfer pricing specialists working alongside the corporate tax and audit teams. Documentation and eligibility assessments are handled together, not separately.

Benchmarking experience across free zone and mainland structures

Senior-led engagements from scoping through to documentation delivery

Common Inquiries

Frequently Asked Questions

It depends on your size and your related-party dealings. Master File and Local File obligations apply at AED 200 million of own revenue or AED 3.15 billion of group consolidated revenue. Businesses below these thresholds with related-party or connected-person transactions should still have their pricing benchmarked and disclosed correctly.

A Local File documents the related-party transactions of a specific UAE entity. A Master File gives a group-wide overview of the multinational's business and transfer pricing policies. Both apply above the revenue thresholds above.

Yes. Complying with the arm's length principle and transfer pricing documentation requirements is one of the conditions for maintaining QFZP status and the 0% rate on qualifying income.

Undocumented or unsupported related-party pricing can be challenged by the FTA. That can mean adjustments and penalties, and it can put QFZP status at risk.

Requirements scale with size and the nature of related-party dealings. Even smaller groups with related-party or connected-person transactions should have their pricing benchmarked and disclosed correctly.

Arm's Length Compliance

Benchmark and Defend Your Related-Party Pricing

Ensure your group meets all transfer pricing documentation and disclosure requirements with expert support from FinApt Group's tax specialists.