Transfer Pricing Advisory & Benchmarking Services
The introduction of UAE Corporate Tax under Federal Decree-Law No. 47 of 2022 has
significantly increased regulatory scrutiny on related-party and intra-group
transactions. Businesses operating in the UAE must now ensure that such
transactions comply with the arm’s length principle, meaning prices must reflect fair
market value as if the parties were independent. This requirement applies to both mainland and Free Zone
companies, and failure to
comply can lead to tax adjustments, penalties, and increased audit scrutiny by the
Federal Tax Authority (FTA).
At Excellence, we provide comprehensive transfer pricing advisory and
benchmarking services in the UAE, aligned with:
- UAE Corporate Tax Law and Executive Regulations
- Guidance issued by the Federal Tax Authority
- Organisation for Economic Co-operation and Development Transfer Pricing
Guidelines
Our transfer pricing specialists combine technical expertise, economic analysis, and
practical business insights to help organisations implement compliant, defensible,
and commercially practical pricing policies.
Scope of Our Transfer Pricing Services
Transfer Pricing Framework & Policy Development
We assist businesses in designing and implementing Transfer Pricing policies and
intercompany agreements that clearly define pricing mechanisms for transactions
between related entities.
These may include:
- Management and technical service fees
- Royalty and intellectual property arrangements
- Distribution and procurement models
- Intercompany financing and guarantees
- Cost allocations and shared service arrangements
Our policies are tailored to the group’s operational structure and UAE regulatory
requirements, ensuring both compliance and operational practicality.
Functional, Asset & Risk (FAR) Analysis
A Functional, Asset & Risk (FAR) analysis forms the foundation of any transfer
pricing study.
Our specialists conduct a detailed review of each entity’s:
- Functions performed
- Assets employed
- Risks assumed
This analysis helps determine the appropriate transfer pricing method, identify the
tested party, and ensure that profits are allocated according to economic substance.
Arm’s Length Pricing Analysis
We determine arm’s length pricing by selecting and applying the most appropriate
transfer pricing method, supported by benchmarking and economic analysis.
Recognised methods include:
- Comparable Uncontrolled Price (CUP) Method
- Resale Price Method
- Cost Plus Method
- Transactional Net Margin Method (TNMM)
- Profit Split Method
These methods are consistent with OECD Transfer Pricing Guidelines and UAE Corporate Tax regulations.
Transactions typically subject to transfer pricing rules include:
- Sale of goods between related entities
- Management and technical service fees
- Royalty and licensing arrangements
- Intercompany loans and financing
- Cost-sharing and allocation arrangements
Benchmarking & Economic Analysis
Benchmarking is a critical component of transfer pricing compliance, providing independent market evidence that
related-party pricing reflects market conditions. Our benchmarking and economic analysis services help businesses demonstrate that their pricing policies align with
the arm’s length principle, reducing the risk of tax adjustments or disputes.
Comparable Company Search & Selection
We identify independent comparable companies or transactions using structured database searches and screening
filters, including:
- Industry classification and business activity
- Revenue and operational scale
- Financial data reliability
- Intangible asset intensity
- Functional comparability
This process ensures the benchmarking analysis is credible, defensible, and aligned with regulatory expectations.
Profitability & Margin Analysis
We evaluate the tested party’s profitability using appropriate profit level indicators (PLIs) such as:
- Operating margin
- Gross margin
- Mark-up on total cost
- Berry ratio
The financial results are then compared against independent companies to determine the arm’s length range using
accepted statistical tools such as the interquartile range (IQR).
Industry & Market Analysis
Our benchmarking studies incorporate a detailed review of:
- Industry structure and market dynamics
- Competitive environment
- Economic and regulatory conditions
- Geographic market factors
This ensures benchmarking outcomes reflect real-world commercial conditions.
Financial Ratio Benchmarking
We also conduct financial ratio comparisons between the tested party and comparable companies to evaluate:
- Profitability levels
- Cost structures
- Operational efficiency
This analysis supports transfer pricing documentation, strategic planning, and regulatory reviews.
Customized Benchmarking Studies
Our benchmarking studies are tailored to support various business and regulatory requirements, including:
- Transfer Pricing documentation
- Business and asset valuations
- Internal pricing policy development
- Tax audits and regulatory disputes
- FTA information requests and reviews
All analyses are clearly documented, data-driven, and defensible.
Transfer Pricing Documentation (Master File & Local File)
We prepare Master File and Local File documentation in accordance with UAE Corporate Tax requirements.
Documentation typically includes:
- Group structure and ownership details
- Business and value chain analysis
- Description of related-party transactions
- Economic and benchmarking analysis
- Financial comparability adjustments
Maintaining contemporaneous documentation ensures businesses remain prepared for FTA reviews and audits.
Transfer Pricing Disclosure & Compliance Support
We assist companies in preparing and reviewing related-party transaction disclosures required under UAE Corporate
Tax regulations.
Our services ensure:
- Consistency between corporate tax returns and TP documentation
- Accurate reporting of related-party transactions
- Compliance with FTA disclosure requirements
Transfer Pricing Risk Reviews & Health Checks
Our transfer pricing health checks identify potential risk areas and documentation gaps.
This includes reviewing:
- Existing pricing policies
- Intercompany agreements
- Profitability trends
- Benchmarking validity
We then provide practical recommendations to mitigate regulatory and tax risks.
FTA Audit & Enquiry Support
In the event of a tax authority review or audit, our transfer pricing specialists provide technical support,
including:
- Responding to FTA information requests
- Explaining transfer pricing methodologies
- Preparing supporting documentation
- Assisting with dispute resolution
This ensures businesses remain fully prepared and protected during regulatory reviews.
Transfer Pricing Compliance Risks in the UAE
Non-compliance with UAE transfer pricing regulations can result in serious financial and regulatory consequences
for both mainland and Free Zone entities.
Mainland Companies
Companies operating in the UAE mainland may face:
- Adjustments to taxable income by the FTA
- 9% corporate tax applied on the adjusted amounts
- Administrative penalties for non-compliance
- Interest charges of 14% per year on any unpaid tax
Qualifying Free Zone Persons (QFZPs)
Free Zone entities that fail to comply may be subject to:
- Loss of Qualifying Free Zone Person (QFZP) status
- 9% corporate tax applied to the entire income, not just the adjustments
- Revocation of Free Zone tax benefits for a period of five years, applied retroactively
Why Choose Excellence for Transfer Pricing Consulting?
At Excellence, we provide end-to-end transfer pricing advisory services in Dubai and across the UAE, combining
technical expertise with practical business insight.
Our services help businesses:
- Develop compliant transfer pricing policies
- Conduct reliable benchmarking analysis
- Prepare Master File and Local File documentation
- Manage related-party disclosures
- Respond effectively to FTA reviews and audits
All analyses and documentation are structured, transparent, and aligned with international best practices, helping
organisations confidently manage intercompany transactions while remaining compliant with UAE Corporate Tax
regulations.