TRANSFER PRICING
Coordinating Transactions. Justifying Valuations. Preventing Penalties.
Transfer pricing has shifted from being optional compliance to a crucial aspect of international tax governance. We assist you in structuring, documenting, and defending all related-party transactions with clarity and assurance.
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Make Transfer Pricing Your Compliance Advantage, Not a Liability
As the UAE adopts global tax reforms in accordance with the OECD Base Erosion and Profit Shifting (BEPS) Action Plan, transfer pricing has become a fundamental compliance necessity. The Ministry of Finance requires that businesses in the UAE—particularly those involved in cross-border or intra-group dealings—adhere to arm’s length principles, maintain necessary documentation, and remain prepared for audits at any time.
Finjuris Global acts as your strategic ally in establishing and documenting a solid Transfer Pricing framework that aligns with your business model, validates your pricing strategy, and equips you for examination by both local and international tax authorities.
Regardless of whether you are a multinational corporation with intercompany financing, a digital enterprise distributing IP royalties, or a holding company charging management fees to subsidiaries— we ensure your transfer pricing approach is legally defensible, financially viable, and ready for regulatory review.
What is Transfer Pricing?
Transfer pricing regulates how prices are set between affiliated entities within the same corporate group, particularly when these entities function across different tax regions. If these transactions are not priced at "arm’s length" (meaning as though they were between independent parties), they can skew taxable income and lead to audits, penalties, or reclassification.
- Arm’s length principle (ALP)
- Documentation requirements (Local file, Master file)
- Disclosure of controlled transactions
- Country-by-country reporting (CbCR) for larger groups
Our Transfer Pricing Services
Functional & Economic Analysis
We start by identifying the key operations, assets, and risks among your group entities. Next, we assess the nature of the transaction—whether it involves IP licensing, management fees, services, or financing—and illustrate how value is generated.
Benchmarking Studies
Utilizing industry-specific databases, we locate comparable uncontrolled transactions to validate your pricing. This includes margin analysis, royalty benchmarks, and service fee comparisons.
Master File & Local File Preparation
We assist in preparing both the Master File (group-wide) and Local File (specific to each entity) documentation to meet UAE standards in accordance with OECD Action 13.
Intercompany
Agreements
We draft legal contracts that reflect the economic reality of your group’s internal transactions—ensuring alignment between your contracts, financial documentation, and pricing strategies.
Transfer Pricing Policy Design
We develop or enhance your internal transfer pricing policy to guarantee consistent and defensible pricing for management fees, cost allocations, interest on intercompany loans, and royalty payments.
Disclosure & Filing
Advisory
We provide guidance on completing Transfer Pricing Disclosure Forms as mandated with your UAE Corporate Tax Return, and advise on filing deadlines, thresholds, and exception guidelines.
Transfer Pricing Audit Defense
If you encounter scrutiny from the UAE tax authority (FTA) or an international jurisdiction, we prepare detailed documentation and negotiate with regulators or tax auditors to support your pricing.
Why Transfer Pricing is Important in the UAE
Legal Requirement
Documentation for transfer pricing is mandatory for companies involved in transactions with related parties. Failure to comply may result in financial penalties or adjustments to taxable income.
Audit Preparedness
Insufficient documentation during an audit could result in a reclassification of your transactions and potential back taxes.
Global Consistency
Appropriate transfer pricing policies ensure that your UAE operations align with overall group tax strategies, particularly in countries that impose higher tax rates.
Investor Preparedness
Compliance with transfer pricing regulations has become a necessary part of the due diligence process in mergers and acquisitions, joint ventures, and capital raising efforts.
What We Provide
Comprehensive Transfer Pricing documentation that meets
OECD standards
Customized economic and financial evaluationst
Comparative benchmarking across industries
Legally sound intercompany agreements
Strategic protection against audits by tax authorities
Key Reasons why Transfer Pricing Matters
Legal Compliance
The UAE Corporate Tax Law requires businesses to apply the arm’s length principle for all related-party and connected-person transactions. Non-compliance can result in tax adjustments, penalties, and loss of tax exemptions, especially for Free Zone entities.
Audit Preparedness
The Federal Tax Authority (FTA) has the right to request transfer pricing documentation within 30 days of notice. Businesses lacking timely and adequate documentation may face unfavorable reassessments and increased regulatory scrutiny.
Global Consistency & Risk Mitigation
Multinational enterprises operating in the UAE must align their pricing structures across jurisdictions. Consistent and defensible transfer pricing policies help mitigate double taxation, resolve disputes, and ensure smooth cross-border operations.
Reputational Credibility
Transparent and compliant pricing structures reflect strong corporate governance. This is particularly important during due diligence processes, such as mergers, acquisitions, joint ventures, or international expansion.
Tax Efficiency
A well-structured transfer pricing policy can support tax optimization within legal frameworks by aligning pricing strategies with economic substance and operational realities.
In short, transfer pricing is not just a tax requirement, it's a strategic necessity.
By establishing a compliant and defensible Transfer Pricing framework, businesses in the UAE can minimize tax risk, enhance investor trust, and maintain long-term operational credibility.
Why should you choose Finjuris for Transfer Pricing Compliance?
Strategic Clarity. Regulatory Precision. International Readiness.
At Finjuris Global, we empower your business to transform regulatory obligations into competitive strengths. Transfer Pricing is no longer optional; it's a cornerstone of responsible international tax governance. Our multidisciplinary team of tax advisors and legal professionals ensures that your intra-group transactions are both compliant and commercially sound.
We don’t just document. We strategize, structure, and defend.What sets us apart?
Region-Specific Expertise
In-depth understanding of UAE Corporate Tax Law, Free Zone frameworks, and transfer pricing obligations ensures your compliance is aligned with local nuances.
OECD-Aligned Methodologies
We follow BEPS Action Plan standards, ensuring your documentation stands up to global scrutiny and cross-border consistency.
Cross-Industry Benchmarking
Using reliable databases, we conduct accurate benchmarking studies across sectors from fintech and logistics to manufacturing and IP licensing.
Audit-Ready Documentation
We build robust files and intercompany agreements that withstand FTA and international audits.
End-to-End Lifecycle Support
From transaction structuring to policy drafting and dispute resolution, Finjuris is with you at every stage of the transfer pricing lifecycle.
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