← TheAuditors.ai
Transfer Pricing Platform

UAE Transfer Pricing Study & Benchmarking Solution

Analyse related-party transactions, prepare benchmarking support and maintain Corporate Tax compliance documentation through an integrated digital platform.

  • Transfer Pricing Study
  • Benchmarking Analysis
  • Related Party Transaction Review
  • Local File and Master File support
  • Corporate Tax compliance
  • Audit-ready documentation
  • UAE Corporate Tax Ready
  • Industry-Specific Analysis
  • Benchmarking Support
  • Audit Trail
  • Integrated With Audit & Tax Modules
  • Secure Document Management

Quick answer

What is a UAE transfer pricing study and who needs one?

A transfer pricing study evaluates whether transactions between related parties and connected persons — management fees, intercompany services, loans, royalties, goods trading, cost allocations and guarantees — are priced on the arm's length principle required under UAE Corporate Tax. It documents the parties, the functions performed, assets used and risks assumed, selects a pricing method and supports the position with benchmarking against comparable data. Whether a UAE business must maintain a Local File or Master File depends on its profile and thresholds under Federal Tax Authority (FTA) rules, but any entity with related-party transactions should be able to evidence an arm's length position.

Arm's length principle
The standard requiring related-party prices to reflect what independent parties would have agreed in comparable circumstances.
Functional analysis (FAR)
Analysis of the functions performed, assets used and risks assumed by each party, used to characterise the parties and select a method.
Benchmarking
Comparison of the tested party's pricing or margin against a set of comparable independent companies or transactions.
Local File and Master File
Entity-level and group-level transfer pricing documentation required where the applicable Corporate Tax thresholds are met.

Overview

Structured transfer pricing documentation for UAE businesses

UAE businesses increasingly need structured transfer pricing documentation to support related-party transactions under Corporate Tax requirements.

TheAuditors.ai combines professional advisory workflows with technology to help businesses identify related-party transactions, analyse pricing approaches, prepare documentation and maintain audit-ready records.

  • CFOs and finance managers
  • Business owners and family groups
  • Tax teams and audit firms
  • Holding companies
  • Free zone and mainland entities
  • Multinational groups

TheAuditors.ai AML Compliance Platform

Identify compliance risks before they become business problems.

Explore AML Platform

Foundations

What is a Transfer Pricing Study?

A Transfer Pricing Study evaluates whether transactions between related parties are conducted under the arm's length principle.

The arm's length test

  • Evaluates whether related-party transactions are conducted under the arm's length principle
  • Considers whether pricing reflects what independent parties would have agreed under comparable circumstances

What the study reviews

  • Transaction nature
  • Parties involved
  • Functions performed
  • Assets used
  • Risks assumed
  • Market comparables
  • Pricing methodology

UAE compliance

UAE Transfer Pricing Compliance — related party transactions

TheAuditors.ai helps businesses address UAE Corporate Tax transfer pricing requirements. Select a transaction type to see what the analysis covers.

Management fees

Charges from a parent or group entity for strategic, executive or administrative oversight — supported by evidence of the service, the benefit received and an arm's length charge.

Industry solutions

Industry-Specific Transfer Pricing Studies

Benchmarking is not one-size-fits-all — each sector carries its own transactions, functions, risks and comparable data.

Trading & Distribution Companies

Transfer Pricing Study for UAE Trading Businesses

Transactions reviewed

  • Import purchases
  • Distribution arrangements
  • Group supplier transactions
  • Sales commissions

Analysis

  • Distributor functions
  • Inventory risks
  • Market margins
  • Pricing models

Methods considered

CUPResale Price MethodTNMM

Manufacturing Companies

Transfer Pricing Study for UAE Manufacturers

Transactions reviewed

  • Raw material purchases
  • Contract manufacturing
  • Technical services
  • Production support

Analysis

  • Manufacturing functions
  • Cost structures
  • Capacity utilisation
  • Profitability

Methods considered

Cost PlusTNMM

Real Estate Groups

Transfer Pricing Study for Real Estate Companies

Transactions reviewed

  • Property management fees
  • Development services
  • Related-party financing
  • Shared costs

Analysis

  • Asset ownership
  • Development risks
  • Financing arrangements

Methods considered

CUPCost PlusTNMM

Construction Companies

Transfer Pricing Study for Contractors

Transactions reviewed

  • Project support fees
  • Equipment sharing
  • Engineering services
  • Group resources

Analysis

  • Project risks
  • Contract terms
  • Cost allocation

Methods considered

Cost PlusTNMM

Gold, Diamond & Precious Metals

Transfer Pricing Study for Gold & Jewellery Businesses

Transactions reviewed

  • Commodity pricing
  • International pricing references
  • Inventory valuation
  • Import/export transactions
  • Related-party purchases

Analysis

  • Gold traders
  • Jewellery companies
  • Diamond dealers
  • Refiners
  • Precious metal businesses

Methods considered

CUPResale Price MethodTNMM

Hospitality & Restaurants

Transfer Pricing Study for Hospitality Groups

Transactions reviewed

  • Franchise fees
  • Brand charges
  • Management fees
  • Central procurement

Analysis

  • Brand ownership
  • Operator functions
  • Procurement benefit

Methods considered

CUPTNMMProfit Split

Healthcare

Transfer Pricing Study for Healthcare Providers

Transactions reviewed

  • Medical equipment arrangements
  • Group services
  • Procurement
  • Technical support

Analysis

  • Asset ownership
  • Service functions
  • Regulatory risk

Methods considered

CUPCost PlusTNMM

Technology & Software

Transfer Pricing Study for Technology Companies

Transactions reviewed

  • Software licensing
  • IP arrangements
  • Development services
  • Cloud services

Analysis

  • IP ownership and DEMPE functions
  • Development risk
  • Routine versus entrepreneurial returns

Methods considered

CUPCost PlusTNMMProfit Split

Financial Services

Transfer Pricing Study for Financial Groups

Transactions reviewed

  • Related-party loans
  • Guarantees
  • Advisory services
  • Investment structures

Analysis

  • Credit rating
  • Capital and liquidity
  • Risk-bearing capacity

Methods considered

CUPTNMM

Family Businesses & Holding Companies

Transfer Pricing Study for Family Groups

Transactions reviewed

  • Management charges
  • Shared services
  • Intercompany loans
  • Asset transfers

Analysis

  • Group structure
  • Ownership relationships
  • Business purpose of each charge

Methods considered

CUPCost PlusTNMM

Workflow

How the TheAuditors.ai Transfer Pricing workflow works

  1. 1

    Entity & relationship mapping

    Create the company profile, group structure, ownership relationships and related-party register from the central client master.

  2. 2

    Transaction identification

    Capture each transaction type, amount, counterparty, agreement and business purpose — pulled from the ledger where the accounting module is connected.

  3. 3

    Functional analysis

    Document functions (who performs activities), assets (what resources are used) and risks (who assumes commercial risks) for each party.

  4. 4

    Benchmarking analysis

    Analyse comparable companies, industry data, financial indicators and profitability ranges to support the arm's length position.

  5. 5

    Documentation generation

    Generate the Transfer Pricing Study, Benchmarking Report, Related Party Analysis and supporting schedules with a full review and approval trail.

Integration

Integrated with the TheAuditors.ai ecosystem

Transfer pricing does not sit in isolation — it draws on and feeds every connected module.

Corporate Tax Module

  • Related party disclosures
  • Tax adjustments
  • Compliance tracking

Audit Module

  • Audit evidence
  • Related party testing
  • Documentation review

Accounting Module

  • Ledger analysis
  • Transaction identification
  • Reconciliation

IFRS Module

  • Financial instrument review
  • Related party disclosures
  • Valuation support

AML Module

  • Ownership analysis
  • Related party identification
  • Risk assessment

Documentation

Transfer Pricing Documentation Checklist

The platform requests this information once and reuses it across modules.

Company information

  • Trade licence
  • Ownership structure
  • Group chart
  • Financial statements

Transaction information

  • Related party list
  • Agreements
  • Transaction values
  • Ledger details

Operational information

  • Business model
  • Functions performed
  • Assets used
  • Risks assumed

Why TheAuditors.ai

Why use TheAuditors.ai?

One platform

  • Audit
  • Tax
  • IFRS
  • Accounting
  • Transfer Pricing
  • AML

Connected data

  • Entity profiles
  • Documents
  • Financial data
  • Related party information
  • No repeated information requests

Audit-ready documentation

  • Working papers
  • Supporting evidence
  • Review history
  • Approval workflow

FAQ

Frequently asked questions

Sources

References

UAE Corporate Tax Law

Federal Decree-Law No. 47 of 2022 and Federal Tax Authority guidance

Official source

FTA Transfer Pricing Guide

CTGTP1

Refer to the issuing authority's published document

OECD Transfer Pricing Guidelines

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

Official source

Legal information reviewed: September 2026. Confirm the version of each source in force for the period concerned.

Summary

Key takeaways

  • Transfer pricing applies to any UAE business with related-party transactions — not only multinational groups.
  • A management fee, loan or royalty is defended by functional analysis, method selection and comparables, not by an intercompany invoice alone.
  • Benchmarking is industry-specific: trading, manufacturing, real estate, gold and technology each carry different functions, risks and comparables.
  • Documentation thresholds and disclosure requirements are set by the Corporate Tax rules in force for each period and must be confirmed.
  • Transfer pricing outcomes flow into the Corporate Tax return, the audit file and IFRS related-party disclosures — the data should be entered once and reused.

Primary sources

  • Federal Tax Authority (FTA) — published guides, public clarifications and decisions
  • UAE federal tax legislation — the applicable Federal Decree-Law and its Executive Regulations, as amended
  • Cabinet and Ministerial Decisions — issued under the relevant tax law
  • FTA Transfer Pricing Guide (CTGTP1) — for arm's length analysis, methods, comparability and documentation requirements
  • OECD Transfer Pricing Guidelines — used as interpretative guidance where the applicable law permits

References are provided so positions can be verified against the current text of the applicable law, guidance or standard. Requirements change; always confirm the version in force for the period concerned.

Last updated
16 August 2026
Reviewed by
Transfer Pricing & Corporate Tax team
Content owner
Head of the relevant service line
Next review due
12 February 2027

Videos

Watch our UAE Transfer Pricing Study & Benchmarking Platform videos

Get in touch

Need help with UAE transfer pricing?

Need help with UAE transfer pricing?

Start your transfer pricing assessment with TheAuditors.ai. Our advisory team will review your related-party transactions and recommend the documentation required.

PDF, Word or Excel. Uploaded files are stored securely and classified against your enquiry only.

Your submission is checked against our existing records — no duplicate company file is created.

The content on this page is general information about our services. It is not advice and does not create a professional relationship. Tax, accounting and regulatory requirements change; positions depend on the applicable law of the relevant jurisdictions, the version in force for the period concerned and the facts of each case.