Is the price supportable?
Understand the actual transaction and arm’s-length position. Establish what independent parties would consider in comparable circumstances.
05 / CONNECT PRICE TO SUBSTANCE
Transfer Pricing Services in Dubai.
Related businesses.
Defensible transactions.
Transfer pricing reviews whether related-party transactions are supported on an arm’s-length basis. A&A helps map the transactions, examine their commercial substance and scope the evidence and documentation required.
THREE DIFFERENT QUESTIONS
Pricing, disclosure and documentation
are not the same test.
What must be disclosed?
Assess the current return questions and applicable reporting requirements. Reconcile transaction totals to the ledger and identify the relevant counterparties.
Which files are needed?
Check formal documentation requirements separately. Define the master file, local file, study or other support required for the actual entity and period.
FOLLOW THE COMMERCIAL STORY
Who does the work?
Who earns the return?
Functions
Who negotiates contracts, manages customers, delivers services and makes operating decisions?
Assets
Which entity uses equipment, systems, funding or intellectual property to deliver the transaction?
Risks
Who controls the significant risks and has the financial capacity to bear them in practice?
A functions, assets and risks review links the contract to real conduct. Interviews and operating evidence matter alongside financial data. We record inconsistencies before a pricing policy is treated as implemented.
Build evidence around the transaction.
| Transaction | Starting records | Question that strengthens the file |
|---|---|---|
| Management service charge | Agreement, delivery records and allocation workings | What benefit did each recipient receive? |
| Intercompany loan | Terms, currency, tenor and borrower information | How are credit risk and financing terms supported? |
| Goods distribution | Invoices, functions and segmented results | Are the tested activities and comparables consistent? |
| Cost sharing / recharge | Cost pool, exclusions and allocation keys | Why does the allocation reflect use or benefit? |
A useful example: a shared finance team
A group reallocates finance costs to two businesses. Equal ownership does not automatically justify a 50:50 charge. First identify services delivered, exclude unrelated costs, document the recipients’ benefit and assess an appropriate allocation and pricing method. This is an evidence example, not a prescribed markup or approved pricing policy.
FROM MAPPING TO MAINTENANCE
A file that matches the way you operate.
- Map counterparties, relationships and transaction categories.
- Reconcile transaction values and interview the people doing the work.
- Evaluate the method, evidence gaps and documentation requirements.
- Agree changes, retain approval and review actual year-end outcomes.
Keep the owner of each policy visible. A report becomes less useful if new transactions, pricing changes or operational changes are never reflected in it.
Connect the review to Corporate Tax filing →Scope the engagement before commissioning a study.
Transaction review
Useful when the first task is understanding the relationships, material transactions and quality of available evidence. The output is a scoped issue list, not an automatic certification of every price.
Documentation project
Define entities, years, transactions, file requirements and responsibility for data. Agree any external database research and specialist input before quoting a full documentation package.
Implementation support
Translate the agreed position into contracts, allocation workings and accounting procedures. Review whether actual results remain consistent with the policy, with changes documented as they arise.
CLEAR ANSWERS
Your questions,
before you begin.
General UAE guidance, with the details of your entity and tax period checked before we advise.
Does transfer pricing matter below the master-file threshold?
Yes. A threshold for a formal documentation requirement is not a blanket exemption from the arm’s-length principle. Keep proportionate evidence supporting the relevant related-party transactions and assess disclosure obligations separately.
Are domestic related-party transactions relevant?
They can be. Do not restrict the review to payments overseas. Map the relationship, transaction and applicable treatment even where both counterparties are in the UAE.
Is an intercompany agreement enough?
An agreement records the intended arrangement but does not prove the price or actual conduct. It should be consistent with services delivered, functions performed, assets used, risks and accounting records.
Can the same markup be used for every service?
Not automatically. The nature of the service, cost base, recipient benefit and comparability matter. Do not choose a percentage simply because another group uses it; document the method and evidence for the transaction.
Do you prepare master files, local files and benchmarking studies?
We first assess which work is required and agree the deliverables. Formal files and external benchmarking require a defined scope, reliable data and appropriate resources. They are not automatically included in a basic transaction review.
Does a report guarantee acceptance by the FTA?
No. Documentation supports a position but the authority may ask questions or challenge it. We identify assumptions and evidence limitations rather than describe a report as pre-approved or risk-free.
Official sources & scope
Content checked on 11 September 2026. This page explains a consultancy service; it is not an FTA ruling, a legal opinion or a guarantee of approval. The law and decisions applicable to your period take precedence over summaries.
Fees and delivery dates depend on the records, entities, transactions and work agreed. Government charges, tax payable and penalties are separate from our professional fees. Do not send passwords or one-time codes through an enquiry form.
A&A TAX CONSULTANTS · DUBAI & UAE
Start with your business.
Leave with a clear next step.
Tell us the service you need, your entity type and the relevant period. We’ll clarify the scope and the information needed before work begins.