Transfer Pricing
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Transfer Pricing Services in Sharjah, UAE
Transfer pricing rules came into force with UAE Corporate Tax. They require transactions with related parties and connected persons to be priced as if the parties were independent, on an arm’s length basis. If your pricing cannot be supported, the Federal Tax Authority (FTA) can adjust your taxable income.
At Hussain Al Shemsi Chartered Accountants, our tax team in Sharjah helps groups and family businesses identify their related party transactions, test their pricing, prepare the right documentation and complete the disclosures that go with the Corporate Tax return.
UAE transfer pricing at a glance
- Legal basis: Federal Decree-Law No. 47 of 2022 on Corporate Tax, mainly Articles 34 to 36 (arm’s length principle, related parties and connected persons) and Article 55 (documentation).
- Arm’s length standard: follows the OECD Transfer Pricing Guidelines.
- Master file and local file: required where the business has revenue of AED 200 million or more, or belongs to a multinational group with consolidated revenue of AED 3.15 billion or more (Ministerial Decision No. 97 of 2023).
- On request: transfer pricing documentation must be provided to the FTA within 30 days of a request.
- Disclosure form: related party and connected person transactions are reported in a disclosure filed with the annual Corporate Tax return.
How can we help you?
Get in touch with Hussain Al Shemsi Chartered Accountants for expert auditing, accounting, tax, and advisory services in the UAE.
- +971 50 3636231
Our Transfer Pricing Services
Related party and connected person mapping
Identifying who counts as a related party or connected person under the Corporate Tax Law, and which transactions are in scope.
Transfer pricing risk review
Reviewing intra-group pricing, management fees, loans and cost sharing to spot exposure before the FTA does.
Benchmarking and arm's length analysis
Selecting the right method and comparables to support your prices.
Master file and local file
Preparing documentation that meets Ministerial Decision No. 97 of 2023 and stands up to an FTA request.
Transfer pricing disclosure form
Preparing the related party and connected person disclosure filed with your Corporate Tax return.
Intercompany agreements and policies
Drafting or reviewing agreements and a group transfer pricing policy that match how the business actually operates.
Transactions We Commonly Review
- Sale and purchase of goods between group companies
- Management, technical and shared service fees
- Intra-group loans, guarantees and cash pooling
- Royalties and use of brands or intellectual property
- Cost sharing and recharges
- Transfers of assets or business lines
- Payments and benefits to owners, directors and their relatives (connected persons)
- Transactions with free zone entities and Qualifying Free Zone Persons
Who Needs Transfer Pricing Support?
- Groups with UAE companies trading with each other or with foreign affiliates
- Free zone companies dealing with mainland related parties
- Family businesses paying owners, directors or relatives for services
- Businesses above the master file and local file thresholds
- Companies that have received an FTA request for transfer pricing information
Our Transfer Pricing Process
- Scope: we map your group, related parties, connected persons and transactions.
- Analyse: we review contracts, functions, assets and risks for each transaction.
- Test: we apply the appropriate transfer pricing method and benchmark the results.
- Document: we prepare the disclosure form, and the master file and local file where required.
- Support: we help you respond to FTA requests and update your policy each year.
Why Choose Hussain Al Shemsi
- Corporate Tax and transfer pricing together: the disclosure, the return and the documentation tell one consistent story. See our Corporate Tax services.
- Chartered Accountants who also understand your audited financial statements. See our statutory audit services.
- Practical, proportionate documentation sized to your business, not a one-size template.
- Based in Sharjah, supporting mainland and free zone groups across the UAE.
Frequently Asked Questions
What is transfer pricing under UAE Corporate Tax?
It is the set of rules that requires transactions between related parties and connected persons to be priced on an arm’s length basis, as if the parties were independent.
Who are related parties and connected persons?
Related parties include group companies and individuals linked by ownership or control. Connected persons include owners, directors and officers of the business and their related parties.
Do we need a master file and local file?
Yes, if your revenue is AED 200 million or more, or you are part of a multinational group with consolidated revenue of AED 3.15 billion or more, under Ministerial Decision No. 97 of 2023.
What if we are below those thresholds?
You still need to apply the arm’s length principle, report qualifying transactions in the disclosure form and be able to support your pricing if the FTA asks.
How quickly must we provide documentation to the FTA?
Within 30 days of the FTA’s request.
Do free zone companies need transfer pricing?
Yes. Transfer pricing applies to free zone companies, and pricing with related parties is important for keeping Qualifying Free Zone Person status.
Which transfer pricing methods are accepted?
The UAE follows the OECD methods, including comparable uncontrolled price, resale price, cost plus, transactional net margin and profit split.
Get Your Transfer Pricing in Order
Talk to our tax team about your related party transactions and what documentation you need.
Official guidance: Federal Tax Authority.
