BEPS-Compliant Transfer Pricing Solutions
End-to-end transfer pricing documentation and advisory services aligned with OECD Guidelines and UAE corporate tax requirements.
Our international tax specialists help multinational enterprises establish and maintain arm's length pricing policies, prepare required documentation, and navigate the complexities of BEPS Pillar Two (GloBE) regulations in the UAE context.
Our Transfer Pricing Services
Master File & Local File
Comprehensive documentation meeting OECD and UAE compliance requirements
Benchmarking Studies
Arm's length range determination using recognized databases and methods
Intercompany Agreements
Drafting and reviewing cross-border transaction documentation
BEPS Pillar Two Advisory
GloBE rules implementation and impact assessment for UAE groups
Dispute Resolution
MAP assistance and audit defense for transfer pricing matters
Policy Design
Developing customized transfer pricing policies for your business model
Transfer Pricing Methodologies
Comparable Uncontrolled Price (CUP)
Comparing prices charged in controlled transactions with uncontrolled transactions
- Most direct method when reliable comparables exist
- Common for commodity transactions
Transactional Net Margin Method (TNMM)
Comparing net profit margins relative to appropriate base
- Most commonly applied method
- Examines operating profit to sales/assets/costs
Cost Plus Method
Markup on costs incurred by supplier of goods/services
- Suitable for manufacturing and services
- Focuses on return on costs
Resale Price Method
Gross margin on resale of purchased goods
- Appropriate for distribution activities
- Focuses on gross margins
BEPS Compliance Framework
We assist multinational enterprises with:
- CbCR notification requirements in the UAE
- Preparation of CbC reports (XML format)
- Risk assessment based on CbCR data
- Filing through the FTA portal
Our Pillar Two services include:
- Impact assessment for UAE headquartered groups
- QDMTT (Qualified Domestic Minimum Top-up Tax) analysis
- IIR (Income Inclusion Rule) readiness
- UTPR (Undertaxed Payments Rule) planning
- GloBE Information Return preparation
Transfer Pricing Support
Get expert assistance with your TP documentation and compliance
Request ConsultationUAE Transfer Pricing Rules
Documentation Requirements
Master File, Local File, and CbCR for qualifying MNE groups
Filing Deadlines
Align with corporate tax return due dates (9 months after FYE)
Penalties
Up to AED 50,000 for incomplete documentation