Transfer Pricing in UAE

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Review related-party transactions, commercial terms, pricing methods, and documentation against the facts of your business.

Transfer Pricing Services in UAE

Transfer Pricing examines whether transactions between Related Parties and Connected Persons are supported under the applicable Corporate Tax rules. Achieverz Zion Group helps organize transaction information, understand the commercial arrangements, and identify documentation needs. The analysis considers the parties’ actual conduct as well as their agreements.


What Is Transfer Pricing?

Transfer Pricing concerns the terms and pricing of transactions between Related Parties and Connected Persons under the applicable tax rules. The analysis considers whether the arrangement is supported by its commercial facts and whether its treatment follows the Arm’s Length Principle.


Our Transfer Pricing Services

Support may cover goods, services, loans, financing, intellectual property, cost allocations, and other intercompany arrangements. We consider actual conduct, functions performed, assets used, risks borne, contract terms, and how the pricing method relates to those facts.


Arm’s Length Principle and Documentation

The Arm’s Length Principle considers conditions independent parties would agree in comparable circumstances. Documentation should explain the parties, transactions, commercial rationale, pricing method, and supporting evidence. Master File and Local File obligations depend on applicable conditions and thresholds; service charges and intercompany financing should also be supported by evidence that reflects how each arrangement operates.

01
Related-Party Transactions

Review goods, services, royalties, cost allocations, and other intercompany arrangements on their facts.

02
Intra-Group Services

Document what was provided, which entity benefited, and the basis for charges and allocations.

03
Loans & Financing

Support terms, borrower circumstances, relevant risks, interest, currency, maturity, and repayment conditions.

04
Master File & Local File

Assess whether documentation files and other evidence are required under the applicable conditions.


Transfer Pricing Support

Related-Party Transactions

Review transaction terms and actual conduct for goods, services, loans, financing, intellectual property, royalties, and cost allocations.

Consider functions performed, assets used, risks assumed, contract terms, and economic context when assessing the pricing approach.

Keep agreements, invoices, financial schedules, pricing analyses, and commercial rationale aligned with how the arrangement operates. Assess Master File and Local File obligations against applicable conditions.


Preparing for Your Engagement

Prepare the group structure, Related Party and Connected Person information, intercompany agreements, transaction values, financial schedules, service descriptions, and financing terms. Explain how pricing is set and what evidence supports commercial benefit and cost allocation.


Establish clearer pricing, documentation, and commercial support for transactions across your business group.

Put Stronger Support Behind Every Related-Party Transaction

We review functions, assets, risks, actual conduct, and supporting records against the arrangement.