NEX Consultants provides transfer pricing advisory and compliance support in Dubai and across the UAE, helping businesses assess related-party transactions, review intercompany pricing policies, prepare transfer pricing documentation and support UAE Corporate Tax compliance. Businesses operating in the UAE increasingly need to understand how transactions between related companies, shareholders, directors and other connected persons are treated under UAE Corporate Tax regulations. Whether you operate a mainland company, a free zone entity, an SME or a multinational group, a clear transfer pricing approach can help support tax compliance, financial transparency and effective corporate governance. NEX Consultants assists businesses with transfer pricing assessments, documentation coordination, benchmarking analysis, related-party transaction reviews and tax compliance support tailored to their business structure. If you are searching for transfer pricing consultants in Dubai, transfer pricing services in the UAE, transfer pricing documentation, transfer pricing benchmarking or UAE Corporate Tax transfer pricing advisory, NEX Consultants can help you assess your requirements and identify the appropriate next steps.
What Is Transfer Pricing?
Transfer pricing refers to the pricing of transactions between related parties, such as companies within the same corporate group. These transactions may include the sale of goods, provision of services, loans, royalties, management fees, intellectual property arrangements and other intercompany dealings. Under the UAE Corporate Tax framework, transactions between related parties must generally comply with the arm’s length principle. This means that the conditions and prices should be consistent with those that independent parties would agree to under comparable circumstances. Transfer pricing rules help ensure that taxable profits are determined appropriately and that transactions between related parties reflect their commercial and economic circumstances. For UAE businesses, transfer pricing is not limited to multinational corporations. Depending on the circumstances, it may also be relevant to locally owned groups, family businesses, companies with common ownership, free zone companies and businesses making payments to connected persons.
Why Are Transfer Pricing Services Important in the UAE?
The UAE introduced Corporate Tax rules that include requirements relating to related parties, connected persons and transfer pricing documentation. These rules apply to qualifying domestic and cross-border transactions, subject to the applicable provisions and conditions. Businesses may need to assess whether their intercompany transactions are commercially justified, appropriately priced and supported by sufficient documentation.
A transfer pricing review can help businesses:
Assess whether related-party transactions follow the arm’s length principle.
Identify transactions that may require disclosure in the UAE Corporate Tax return.
Evaluate whether Master File and Local File documentation requirements apply.
Review management fees, intercompany loans, royalties and service charges.
Support the commercial rationale behind intercompany pricing arrangements.
Identify potential tax compliance risks before filing a Corporate Tax return.
Maintain appropriate records to support their tax positions if requested by the Federal Tax Authority (FTA).
The exact obligations depend on the nature of the transaction, the business structure, the applicable thresholds and other relevant conditions.
Transfer Pricing Services Offered by NEX Consultants
NEX Consultants supports businesses seeking practical transfer pricing advisory and compliance assistance in Dubai and throughout the UAE.
1. Transfer Pricing Assessment and Advisory
Our transfer pricing assessment helps businesses identify their related parties, connected persons and relevant intercompany transactions.
The assessment may cover:
Review of the corporate ownership and group structure.
Identification of related-party and connected-person transactions.
Review of domestic and international intercompany dealings.
Assessment of transfer pricing documentation requirements.
Identification of potential disclosure and compliance obligations.
Recommendations for appropriate documentation and next steps.
This service is useful for businesses preparing for their first UAE Corporate Tax filing, restructuring their group or reviewing existing intercompany arrangements.
2. Transfer Pricing Documentation in the UAE
Transfer pricing documentation helps demonstrate how a business has assessed and applied the arm’s length principle to its transactions.
Depending on the applicable requirements, NEX Consultants can assist with the preparation or coordination of relevant documentation, including:
Transfer pricing documentation assessments.
Related-party transaction summaries.
Functional and economic analysis coordination.
Intercompany pricing policy documentation.
Supporting financial information and transaction records.
Local File preparation or coordination.
Master File preparation or coordination.
Transfer pricing disclosure support.
Documentation requirements are not identical for every taxpayer. We assess the business circumstances and applicable rules before recommending the appropriate scope of work.
3. Transfer Pricing Benchmarking Study
A transfer pricing benchmarking study helps evaluate whether the pricing or profitability associated with a related-party transaction is consistent with comparable independent-party arrangements.
Depending on the transaction, benchmarking may be relevant to:
Intercompany management fees.
Shared service charges.
Administrative and support service fees.
Distribution and trading margins.
Intercompany loans and financing arrangements.
Royalty and intellectual property charges.
Contract manufacturing arrangements.
Other intra-group transactions.
A benchmarking study may involve selecting an appropriate transfer pricing method, analysing comparable transactions or companies, reviewing relevant financial data and documenting the resulting analysis.
The methodology and availability of reliable comparable data depend on the nature of the transaction.
4. Related-Party Transaction Advisory
Transactions between related parties can arise in businesses of all sizes. They may include dealings between parent companies, subsidiaries, sister companies, shareholders and other entities under common ownership or control.
NEX Consultants can assist with reviewing related-party transactions such as:
Sales and purchases between group companies.
Intercompany service agreements.
Management fees charged between entities.
Shared employee and administrative costs.
Intercompany loans and financing.
Royalty and licence payments.
Cross-border service arrangements.
Cost allocation and reimbursement arrangements.
The objective is to help businesses understand the applicable transfer pricing considerations and maintain appropriate supporting records.
5. Connected-Person Payments and Transactions
The UAE Corporate Tax framework also contains specific rules for payments and benefits involving connected persons.
Businesses may need to review payments to directors, owners, shareholders and other persons falling within the applicable definition of a connected person.
Our review can help businesses identify relevant payments, examine their commercial purpose, assess supporting records and understand whether the applicable market-value and deductibility requirements are satisfied.
Each arrangement should be assessed on its own facts, including the applicable statutory conditions and exceptions.
6. UAE Corporate Tax and Transfer Pricing Compliance
Transfer pricing should be considered as part of a company’s wider UAE Corporate Tax compliance process.
NEX Consultants can coordinate transfer pricing reviews with relevant Corporate Tax and accounting work, helping businesses assess:
Related-party transaction disclosures.
Connected-person schedules and supporting records.
Transfer pricing documentation requirements.
Consistency between accounting records and tax return information.
Intercompany agreements and pricing policies.
Documentation readiness for potential FTA enquiries.
This integrated approach can help businesses address transfer pricing considerations alongside their regular tax compliance responsibilities.
7. Transfer Pricing for Free Zone Companies
Free zone companies are not automatically outside the scope of UAE transfer pricing rules. The applicable rules can cover transactions involving related parties and connected persons located in the UAE mainland, another free zone or a foreign jurisdiction.
NEX Consultants can assist free zone businesses with reviewing:
Transactions with other companies in the same group.
Management and administrative service charges.
Intercompany financing arrangements.
Related-party sales and purchases.
Cross-border group services.
Transfer pricing documentation and disclosure considerations.
For businesses seeking to benefit from the UAE’s Qualifying Free Zone Person regime, transfer pricing compliance should be considered alongside the other applicable Corporate Tax conditions. Transfer pricing compliance alone does not guarantee eligibility for the 0% rate.
8. Transfer Pricing for SMEs and Multinational Groups
Transfer pricing requirements vary according to a business’s size, transactions and circumstances.
For small and medium-sized enterprises (SMEs): A proportionate review can help identify relevant related-party transactions, assess applicable obligations and establish a suitable recordkeeping approach.
For multinational enterprise (MNE) groups: More extensive support may be appropriate, including group structure reviews, cross-border transaction analysis, benchmarking and coordination of Master File and Local File documentation.
NEX Consultants can help businesses understand the level of support relevant to their structure rather than assuming that every company needs the same documentation package.
UAE Transfer Pricing Rules: Key Compliance Considerations
The UAE Corporate Tax framework establishes the arm’s length principle and includes rules concerning related parties, connected persons and transfer pricing documentation.
Businesses should distinguish between the general requirement to apply the arm’s length principle and the additional requirements that apply to certain taxpayers.
Master File and Local File requirements
Under the applicable documentation rules, a taxable person may be required to maintain a Master File and Local File if either of the following conditions is met:
The taxable person’s revenue for the relevant tax period is at least AED 200 million; or
The taxable person is part of an MNE group with consolidated group revenue of at least AED 3.15 billion for the relevant tax period.
The applicable conditions, exclusions and scope of transactions should be reviewed before determining the documentation obligation. The relevant files must be made available to the FTA within the prescribed period if requested.
Related-party transaction disclosure
Certain related-party transactions must be disclosed through the relevant UAE Corporate Tax return schedules when the applicable thresholds and conditions are met.
The relevant tests include the aggregate value of related-party transactions and the value of individual transaction categories. Connected-person payments are subject to separate disclosure considerations.
Businesses should confirm the applicable requirements for their specific tax period rather than relying on a general threshold in isolation.
Domestic and cross-border transactions
Transfer pricing rules can apply to transactions between related parties and connected persons whether they are based in the UAE mainland, a UAE free zone or another country.
The applicable treatment depends on the relationship between the parties, the nature of the transaction and the relevant provisions of the UAE Corporate Tax framework.
NEX Consultants can help businesses review these circumstances and determine an appropriate compliance approach.
Our Transfer Pricing Service Process
NEX Consultants follows a structured approach to transfer pricing support.
Step 1: Initial consultation
We understand the business activity, ownership structure, related-party relationships and the nature of the transactions.
Step 2: Transaction review
We identify relevant transactions, which may include management fees, service charges, loans, royalties, trading arrangements and cross-border dealings.
Step 3: Compliance assessment
We assess the relevant transfer pricing requirements and identify documentation or disclosure considerations.
Step 4: Documentation and benchmarking
Where required and agreed, we coordinate or assist with transfer pricing documentation, economic analysis, benchmarking and supporting records.
Step 5: Corporate Tax coordination
We help align the transfer pricing work with relevant accounting information and Corporate Tax compliance processes.
Step 6: Ongoing support
Where needed, businesses can arrange periodic reviews when their transactions, group structures or applicable requirements change.
The scope, deliverables, timeline and professional fees are confirmed after the initial assessment.
Who Should Consider Transfer Pricing Services?
Our services may be relevant to:
UAE mainland companies with related-party transactions.
Free zone companies dealing with group entities.
SMEs owned by the same shareholders or family groups.
Multinational companies operating in the UAE.
Holding companies and corporate groups.
Businesses making management fee or shared service payments.
Companies with intercompany loans or financing arrangements.
Businesses involved in cross-border trade.
Companies preparing or reviewing UAE Corporate Tax returns.
A company does not necessarily need a full benchmarking study or Master File and Local File simply because it has a related-party transaction.
The correct scope should be determined after reviewing the facts and applicable rules.





