Transfer pricing rules were introduced in the UAE with effect from 1 June 2023. These rules apply to intercompany and related-party transactions undertaken during a taxable period by any taxable entity.

BDO provides specialist transfer pricing services to help organisations navigate these requirements. Whether operating as a multinational group or a growing UAE-based business, our tailored solutions are designed to mitigate compliance risk while supporting an effective global tax strategy.

We assist organisations in developing appropriate policies and documentation for Master Files and adopt a modular approach to Local Files to ensure efficient and proportionate compliance coverage. Our comprehensive range of transfer pricing services includes advisory, compliance, and planning support aligned with UAE transfer pricing rules and international standards.

Transfer pricing advisory

We support organisations in understanding the applicability of transfer pricing rules and the potential impact on business operations, transactions, and governance frameworks.

• Impact assessment
  Our transfer pricing impact assessment evaluates the current state of intercompany transactions and identifies potential risks, including exposure to audits, adjustments, or penalties. We review existing arrangements to identify any misalignment with the arm’s length principle and assess compliance with UAE transfer pricing rules and international standards.
• Transfer pricing due diligence
  We provide due diligence support to assess transfer pricing implications arising from mergers, acquisitions, restructurings, and cross-border business changes.
• Profit attribution to permanent establishments
  We assist organisations in determining appropriate profit attribution to permanent establishments, ensuring alignment with international standards. Our services include reviewing allocation keys and analysing cost allocations between headquarters and permanent establishments.
• Cross-functional transfer pricing advisory
  We advise on the interaction between transfer pricing and other tax areas, including VAT implications of transfer pricing adjustments, alignment with customs valuation practices, and the impact of transfer pricing considerations in mergers and acquisitions transactions.

Transfer pricing planning

We support organisations in designing and implementing effective transfer pricing frameworks for intra-group transactions. Our approach ensures that pricing is aligned with the arm’s length principle, complies with UAE Corporate Tax law, and supports commercial objectives.

• Design of transfer pricing policies aligned with business models, operational structures, and strategic objectives
• Implementation of transfer pricing frameworks, including preparation of segmental financial information reflecting arm’s length margins
• Development of transfer pricing-compliant structures supporting tax efficiency and regulatory alignment
• Benchmarking studies to determine arm’s length pricing
• Review of intercompany agreements to ensure compliance with transfer pricing requirements
• Ongoing support and periodic reviews to identify potential gaps and maintain compliance as business models and regulations evolve
• Support with debt structuring considerations aligned with thin capitalisation requirements

Transfer pricing compliance and documentation

Transfer pricing rules require taxable persons to maintain appropriate documentation demonstrating that intercompany and connected person transactions comply with the arm’s length principle. We assist organisations in meeting documentation and compliance obligations in accordance with Federal Tax Authority requirements.

Local File and Master File preparation

Transfer pricing documentation is essential to demonstrate that intercompany and connected person transactions are conducted on arm’s length terms. Organisations meeting the relevant thresholds are required to maintain Local Files and a Master File for each taxable year. We support organisations in preparing, maintaining, and updating documentation to ensure compliance and reduce the risk of penalties.

Transfer pricing disclosure form

We assist organisations in preparing transfer pricing disclosure forms required for reporting intercompany and connected person transactions conducted during the taxable period where Federal Tax Authority thresholds are met.

Country-by-Country Reporting and Advance Pricing Agreements

We support multinational groups in meeting Country-by-Country Reporting obligations and provide guidance on Advance Pricing Agreement procedures to enhance tax certainty and reduce transfer pricing risk.

Why businesses choose BDO in the UAE

• UAE-specific transfer pricing expertise – supporting businesses since the introduction of transfer pricing rules in June 2023
• Modular Local File approach – cost-effective documentation tailored to the size and complexity of each entity
• Cross-functional transfer pricing advisory – aligned with VAT, Corporate Tax, and M&A considerations
• Comprehensive benchmarking studies – supported by internationally recognised databases
• Part of BDO’s global transfer pricing network – coordinated documentation across multiple jurisdictions

Supporting sustainable transfer pricing compliance

Our approach combines technical expertise with practical implementation insight, helping organisations manage transfer pricing risks, maintain compliance, and align tax structures with business strategy.