Transfer Pricing Advisory & Documentation
Transfer Pricing Advisory & Documentation
Align your intercompany transactions with arm's length principles through our robust transfer pricing strategies and comprehensive documentation.
With the implementation of the UAE Corporate Tax regime, Transfer Pricing (TP) has emerged as a critical compliance requirement for multinational enterprises and domestic groups alike. ASPA Management Consultancy assists businesses in navigating these complex regulations, ensuring intercompany pricing policies are defensible, transparent, and fully aligned with OECD guidelines and Federal Tax Authority (FTA) laws.
Strategic Transfer Pricing Advisory:
Our advisory services help you establish pricing models that make commercial sense while mitigating tax risks:
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Evaluation of existing intercompany transactions and supply chain models
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Design and implementation of sustainable transfer pricing policies
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Benchmarking and economic analysis to establish arm's length pricing
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Advisory on corporate restructuring and cross-border intra-group arrangements
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Optimization of intellectual property and intangible asset transfers
Compliance & Documentation Support:
We ensure your business meets all local and global documentation requirements to prevent penalties:
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Preparation of Local File and Master File in accordance with UAE CT Law
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Country-by-Country Reporting (CbCR) compliance and notifications
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Drafting and reviewing comprehensive intercompany agreements
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Defending TP policies during FTA audits and inquiries
We establish robust frameworks that stand up to regulatory scrutiny and protect your profit margins.
Our methodologies are strictly aligned with OECD guidelines to ensure global and local compliance.
What is the "Arm's Length Principle"?
The arm's length principle requires that transactions between related parties (such as a parent company and its subsidiary) be conducted under the same pricing and conditions as if they were between independent, unrelated parties.
Who is required to maintain TP documentation in the UAE?
Taxable persons undertaking transactions with Related Parties and Connected Persons must comply with TP rules. Specific revenue thresholds apply for the mandatory maintenance and submission of a Master File and Local File.
Are domestic transactions subject to Transfer Pricing?
Yes, the UAE Corporate Tax law applies Transfer Pricing rules to both cross-border and domestic transactions between related parties to ensure fair taxation and prevent artificial profit shifting within the UAE.
