Arm's-length policy, benchmarking, Master File / Local File and the Corporate Tax disclosure form under Federal Decree-Law No. 47 of 2022 and Ministerial Decision No. 97 of 2023. Partner-reviewed.
UAE Transfer Pricing (TP) rules apply to transactions between Related Parties and Connected Persons under Articles 34 to 36 of Federal Decree-Law No. 47 of 2022. Every such transaction must meet the arm's-length principle, tested using OECD-aligned methods in the FTA's Transfer Pricing Guide, and a Qualifying Free Zone Person failing TP obligations can lose the 0% rate.
UAE Transfer Pricing (TP) rules apply to transactions between Related Parties and Connected Persons under Articles 34 to 36 of Federal Decree-Law No. 47 of 2022. Every such transaction must meet the arm's-length principle — the price an independent third party would have agreed — tested using one of the OECD-aligned methods set out in the FTA's Transfer Pricing Guide. The rules bite even where both parties are inside the UAE, and they interact directly with Qualifying Free Zone Person status: a QFZP that fails its TP obligations can lose the 0% rate.
Avyanco runs TP as a documentation-and-defence discipline: mapping related-party and connected-person flows, setting a defensible arm's-length policy, preparing the Corporate Tax return disclosure form, and — where the thresholds are met — building the Master File and Local File to the standard the FTA can request within 30 days. TP work is coordinated with the Corporate Tax and audit engagements so one consistent position runs across all three. All TP analysis is partner-reviewed by Vikas Dhingra.
Four engagement types, scaled to the size of the related-party footprint.
Map related-party and connected-person transactions, assess arm's-length exposure and set a defensible group TP policy aligned to the FTA Transfer Pricing Guide.
Economic analysis and comparables benchmarking to evidence that intra-group prices, margins and financing terms sit within an arm's-length range.
Full TP documentation for taxable persons meeting the Ministerial Decision No. 97 of 2023 thresholds — prepared to be produced to the FTA within 30 days of request.
Five steps from transaction mapping to FTA-ready file.
Identify every Related Party and Connected Person flow — goods, services, financing, IP, management charges — and quantify the related-party footprint for the tax period.
Analyse functions, assets and risks across the parties to determine the appropriate arm's-length method and the tested party for each material transaction.
Build comparables searches and economic analysis to establish the arm's-length range for margins, mark-ups and financing terms.
Prepare the disclosure form for the Corporate Tax return and, where thresholds are met, the Master File and Local File to FTA standard.
Support FTA queries and audits, and refresh the policy and documentation each tax period as the business and the rules evolve.
TP is the most technical — and most frequently mis-handled — part of UAE Corporate Tax.
Transfer Pricing run as documentation-and-defence, not a tick-box.
Functional analysis and benchmarking that establish a defensible arm's-length range — not an assertion the FTA can unwind on audit.
TP aligned with the Corporate Tax computation, QFZP positioning and VAT so one consistent related-party story runs across the file.
Transfer-pricing compliance is a QFZP condition — we keep it intact so a free-zone entity's 0% rate survives the annual re-test.
Master File and Local File built to be produced within the 30-day FTA window — not assembled in a panic after the request lands.
Every benchmarking study and TP file is signed off by Vikas Dhingra, CFO and tax practice lead.
Multinational groups supported on Country-by-Country Reporting and Master File consistency across jurisdictions.
Partner-led Transfer Pricing practice — Vikas Dhingra leads alongside Avyanco's Corporate Tax and audit team.
Three things that come up in every TP engagement.
Master File, Local File and benchmarking built to withstand FTA scrutiny within the 30-day production window.
Transfer-pricing compliance preserved as a Qualifying Free Zone Person condition so the 0% rate is not lost on the annual re-test.
TP, Corporate Tax and VAT aligned — related-party flows tell the same story across every return and file.
Recent feedback from groups Avyanco runs Transfer Pricing work for.
I had an excellent experience with Avyanco Business Setup Consultancy for both my company formation and family dependent visa process in the UAE.
Read more — Eder Schaphauser Ziomek's review on GoogleWe had an excellent experience working with this company for our ADGM company setup in Abu Dhabi.
Read more — Nikhil Nadanga's review on GoogleI have been dealing with Akshta for more than a year now and she has been very professional.
Read more — Sherif Ayub's review on GoogleIn so far as the emigration process can ever be made easy, Avyanco achieves exactly this.
Read more — Sheru George's review on GoogleWe are very satisfied with Avyanco's support for Nanasu Realty — especially across AML compliance, accounting, and company setup.
Read more — Purushottam Mukkundi's review on GoogleI've used the services of Avyanco twice over the past 3 years for visa processing, and they have never failed to impress me.
Read more — Dominic Pinto's review on GoogleCommon questions about the UAE Transfer Pricing regime.
Content prepared from publicly available UAE Federal Tax Authority (FTA) guidance, Federal Decree-Law No. 47 of 2022 (Articles 34–36 and 55), Ministerial Decision No. 97 of 2023 on Transfer Pricing documentation, Cabinet Decision No. 100 of 2023 on Qualifying Free Zone Persons and the FTA Transfer Pricing Guide (CTGTP1, October 2023), as of June 2026. Avyanco Business Consultancy LLC is independent of the UAE Federal Tax Authority and not affiliated with any government agency.
Transfer Pricing rules, documentation thresholds, disclosure-form requirements and qualifying conditions evolve. Always confirm the current rules for your specific entity directly with the FTA and a qualified tax advisor before acting on any fact on this page.
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Book a partner-led conversation on related-party policy, benchmarking, the disclosure form or Master / Local File. Coordinated with your Corporate Tax engagement.
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