Transfer Pricing

Understanding Transfer Pricing in the UAE: A Comprehensive Guide

Exploring Transfer Pricing: An Introduction

In the wake of the implementation of UAE Corporate Tax (CT), the concept of Transfer Pricing (TP) has garnered increased attention. The Ministry of Finance (MoF) has recently released a series of documents including “Questions and Answers” and public consultation materials, signaling a significant focus on TP within the UAE’s business landscape.

Unpacking the Concept of Transfer Pricing

At its core, TP refers to the prices of goods and services exchanged between entities with associated parties. Associated parties, in this context, refer to entities or individuals with a prior connection to a business through ownership, control, or familial ties.

Understanding the Implications of Transfer Pricing

TP holds immense significance within corporate taxation frameworks. It directly influences the allocation of profits and losses among taxed entities, thereby impacting the overall tax revenues of a nation.

The Global Perspective on Transfer Pricing

According to the tax justice network, TP serves as a mechanism for multinational corporations to maneuver profits away from high-tax jurisdictions into tax havens. This underscores the critical role of transfer pricing regulations in preventing profit shifting practices.

Key Principles of Transfer Pricing Regulations

Transfer pricing regulations aim to enforce the arm’s length principle, ensuring that transactions between related parties are conducted at prices comparable to those between unrelated parties. Adherence to this principle mitigates the risk of tax base erosion and profit shifting.

Real-Life Implications of Transfer Pricing

Consider a scenario where Company A, domiciled in Bangladesh, sells electronic devices to Company B, a UAE-based entity, for resale in various markets. The variance in corporate tax rates between the two jurisdictions may incentivize strategic pricing decisions to optimize tax liabilities.

Navigating Transfer Pricing Compliance

The implementation of TP rules in the UAE necessitates compliance from businesses engaged in transactions with related parties. The guidelines outlined by the OECD TP Guidelines serve as a benchmark for adhering to arm’s length principles.

Identifying Related Parties and Connected Persons

Related parties encompass individuals or entities with established connections to a business, whereas connected persons include individuals associated with the taxpayer, such as owners, directors, or partners. Both categories are subject to stringent transfer pricing regulations.

Compliance Obligations and Documentation Requirements

Under UAE Corporate Tax Legislation, taxpayers engaged in intercompany transactions must maintain comprehensive documentation to substantiate the arm’s length nature of their transactions. This includes the preparation of local files and master files in accordance with international standards.


In conclusion, TP stands as a critical aspect of modern taxation frameworks, particularly in the context of multinational business operations. By ensuring adherence to arm’s length principles and robust compliance measures, countries like the UAE can safeguard their tax revenues while promoting fair and transparent business practices.