UAE Corporate Tax law codifies the arm's-length principle. Goods, services, royalties, and financing between your head office and your UAE entity all fall within the transfer-pricing rules, and related-party disclosures accompany the tax return.
The hard part is consistency: documentation filed at home and documentation kept in the UAE must tell the same story. Our team — trained in a Big 4 tax practice — designs policies and files that hold together in both places.
What we do
- Policy design — pricing policies and benchmarking for intra-group transactions
- Documentation — master file, local file, and disclosure-form support
- Risk diagnostics — review of existing arrangements and remediation
- BEPS 2.0 / Pillar Two — global minimum tax impact analysis, including the UAE DMTT
- Controversy support — TP queries, APA and MAP procedures
Who this is for
- UAE subsidiaries and branches transacting with a foreign parent
- Groups unsure whether master/local file thresholds apply
- UAE entities of multinational groups within Pillar Two scope
Note
Rates and thresholds on this page are general guidance as of July 2026. Actual treatment depends on your business structure, industry, and financial year — please contact us for a specific review.
Frequently Asked Questions
Who must prepare transfer-pricing documentation?
Any entity with related-party transactions faces disclosure obligations with its return; master and local files apply above certain group or entity revenue thresholds, which change with regulation. We confirm your position based on group facts.
We already have TP documentation at home. Is a UAE file still needed?
Yes — but the two must be consistent. Separate, contradictory files are the riskiest outcome of all.
Does Pillar Two affect us?
If group consolidated revenue is at least EUR 750 million, your UAE entity may fall within the 15% global minimum tax, including the UAE domestic minimum top-up tax. Early modelling is essential.