Who has to comply with UAE transfer pricing rules?

Any taxable person with transactions between related parties or connected persons is subject to the arm's length principle. Disclosure and documentation obligations increase with the size and value of those transactions.

When is a Local File and Master File required?

Where a taxable person's revenue reaches AED 200 million in a tax period, or the business is part of a multinational group above the relevant size, a Local File and Master File must be maintained.

What is the arm's length principle?

It requires transactions between related parties to be priced as if the parties were independent — the same terms an unrelated buyer and seller would agree under comparable circumstances.

Transfer Pricing · United Arab Emirates

Transfer Pricing

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Disclosure forms, Local and Master Files and benchmarking under the UAE's Corporate Tax transfer pricing rules — coordinated end to end, with MHBC as your single point of contact.

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The UAE Corporate Tax regime applies transfer pricing rules aligned with the OECD Guidelines. Transactions between related parties and connected persons must follow the arm's length principle — priced as they would be between independent parties. Businesses disclose qualifying related-party transactions with their Corporate Tax return, and must maintain a Local File and Master File where revenue reaches AED 200 million in a tax period or the business belongs to a large multinational group.

What this service covers

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Identification of related-party and connected-person transactions, and preparation of the disclosure filed with your Corporate Tax return.

Transfer pricing disclosure form

Related parties
Disclosure

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Preparation of the documentation required where the thresholds are met, describing your transactions and the group they sit within.

Local & Master File

Local File
Master File

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Comparability analysis that tests whether intercompany prices meet the arm's length standard, using recognised OECD methods.

Benchmarking

Arm's length
OECD methods

One-time

First-year documentation setup and benchmarking of existing intercompany arrangements.

Recurring

Annual disclosure, with documentation refreshed each tax period as transactions change.

Audit, legal drafting and regulated tax matters are carried out by licensed auditors, registered tax consultants and lawyers within MHBC's team and partner network. MHBC coordinates their work and remains your single point of contact throughout.

Frequently asked

Questions, answered plainly.

Who has to comply with UAE transfer pricing rules?: Any taxable person with transactions between related parties or connected persons is subject to the arm's length principle. Disclosure and documentation obligations increase with the size and value of those transactions.
When is a Local File and Master File required?: Where a taxable person's revenue reaches AED 200 million in a tax period, or the business is part of a multinational group above the relevant size, a Local File and Master File must be maintained.
What is the arm's length principle?: It requires transactions between related parties to be priced as if the parties were independent — the same terms an unrelated buyer and seller would agree under comparable circumstances.

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