Intra-Group Transactions vs Related Party: Transfer Pricing in UAE Tax Groups
A UAE Tax Group is treated as a single Taxable Person for Corporate Tax purposes.…
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Who it’s for
Groups with intercompany transactions — companies that trade, lend, license IP, or share services with related entities in the UAE or abroad.
Founder-owned businesses — where salaries, bonuses, and other payments to owners, directors, or their relatives (Connected Persons) must be justified as market rate.
Free Zone companies (incl. QFZPs) — Qualifying Free Zone Persons that must disclose every related party transaction to protect their 0% status.
Multinationals and scaleups — groups approaching Master File / Local File or Country-by-Country Reporting thresholds.
What you get
Related party & Connected Person mapping
We identify all controlled transactions and who counts as a Related Party or Connected Person under the UAE CT Law.
Arm’s length benchmarking
Functional analysis and pricing studies using the appropriate OECD-aligned methods (CUP, Resale Price, Cost Plus, TNMM, Profit Split).
Salary & remuneration benchmarking
Market-rate benchmarking for salaries, bonuses, and management or director fees paid to Connected Persons, with a short report you can attach to your CT file.
TP Disclosure Form support
Preparation of the related party transactions schedule that forms part of your Corporate Tax return.
Master File & Local File
Full transfer pricing documentation for businesses that exceed the FTA thresholds.
TP policy design
Practical, defensible intercompany pricing policies and intercompany agreements you can actually operate.
Audit & FTA query support
We stand behind the numbers and respond to FTA requests and reviews.
Skrooge (AI) integration
Your related party data, contracts, and balances stay organized and ready, so documentation and disclosures are fast and consistent.
Why Skrooge
One partner for tax + TP
Transfer pricing sits on top of your Accounting & Tax and Corporate Tax foundation, handled under one roof instead of a patchwork of advisors.
UAE-specific expertise
We apply FTA Transfer Pricing Guide rules, OECD principles, and UAE nuances like Connected Persons and Free Zone (QFZP) requirements.
AI + expert combo
Skrooge organizes and processes your data; senior tax specialists build and review the analysis, making TP faster, more accurate, and more affordable.
Defensible, not just compliant
Documentation designed to hold up in an FTA review or audit, not box-ticking.
How we work
Diagnosis & scoping
We review your group structure, related party transactions, and volumes to confirm what’s in scope and what documentation you actually need.
Data collection
You share intercompany agreements, invoices, ledgers, and group information against a clear checklist, so this is fast.
Functional & benchmarking analysis
We analyze functions, assets, and risks, select the most appropriate method, and benchmark to the arm’s length range.
Documentation & disclosure
We prepare your TP Disclosure Form, and where required, the Master File and Local File, and align them with your CT return.
Ongoing support
We keep documentation current each tax period and support you through any FTA queries or audits.
Where we operate
We support businesses across the UAE.
- Mainland: Dubai, Abu Dhabi, Sharjah, Ajman, RAK, UAQ & Fujairah
- Free Zones: DMCC, JAFZA, DIFC, ADGM, Meydan, RAKEZ, IFZA, etc.
Pricing
Custom
Tailored to your related party transactions, group structure and required documentation (Disclosure Form, Local File, Master File).
Get a Tailored QuoteFrequently
Asked Questions
Still have questions? You can
email us on info@skrooge.ai
or submit your request
What is transfer pricing?
Transfer pricing is the pricing of transactions between related parties — for example, sales, services, loans, or IP licensing between companies in the same group, or between a company and its owners or directors. Under UAE Corporate Tax, these transactions must be priced as if they were between independent parties: the "arm's length principle."
Who needs transfer pricing in the UAE?
Any business with transactions involving Related Parties or Connected Persons. This includes groups with intercompany dealings, founder-owned companies transacting with owners or directors, and Free Zone entities. Qualifying Free Zone Persons must disclose every related party transaction regardless of value.
What is the arm's length principle?
It means related party transactions must be priced the same way they would be if the parties were unrelated and dealing independently. If your pricing isn't at arm's length, you may need to make adjustments in your tax return — and the FTA can challenge it.
What documentation do I need?
It depends on your size and transactions. Most taxpayers report related party transactions via the TP Disclosure Form in the Corporate Tax return. Businesses that exceed the FTA thresholds must also maintain a Master File and Local File, and the largest multinational groups may need Country-by-Country Reporting.
Do owner and director salaries need benchmarking?
Yes. Salaries, bonuses, and management fees paid to owners, directors, or their relatives are payments to Connected Persons and are only deductible up to market value. A short benchmarking exercise shows what a comparable independent role would be paid and documents why your remuneration is at arm's length.
What happens if I don't comply?
Non-compliance can lead to FTA adjustments to your taxable income, additional Corporate Tax, and penalties. Free Zone entities risk losing their 0% Qualifying status. Proper documentation protects you in an audit or review.
How much do transfer pricing services cost?
Pricing is custom and depends on the number and complexity of your related party transactions, your group structure, and how much documentation you need. It builds on our Accounting & Tax and Corporate Tax services. Contact us for a tailored quote.
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