Comprehensive Transfer Pricing (TP) solutions aligned with UAE Federal Tax Authority (FTA) requirements, OECD Guidelines, and Ministerial Decision No. 97 of 2023.
End-to-end Transfer Pricing advisory aligned with UAE Federal Tax Authority requirements, OECD Transfer Pricing Guidelines, and international best practices.
Comprehensive comparability analysis using OECD-compliant methodologies to establish arm's length pricing for intercompany transactions.
Specialized compliance for Article 36 transactions including KMP remuneration, director fees, and owner compensation.
Strategic evaluation of all transactions with entities meeting Article 35 criteria under UAE Corporate Tax Law.
Deadline: With CT Return
Mandatory component of the UAE Corporate Tax Return requiring disclosure of Related Party and Connected Persons transactions.
BCL prepares and files TP Disclosure Forms ensuring all thresholds are correctly assessed, schedules properly completed, and adjustments accurately calculated.
Deadline: 9 months from tax period end
Global overview of multinational group's business operations, organizational structure, and transfer pricing policies.
BCL coordinates with group headquarters to prepare Master Files that provide a coherent global picture while meeting UAE-specific requirements.
Deadline: 9 months from tax period end
Detailed Transfer Pricing Study documenting controlled transactions for a specific tax period per Ministerial Decision No. 97 of 2023.
BCL delivers comprehensive Local Files that withstand FTA scrutiny, incorporating rigorous economic analysis and contemporaneous documentation.
Deadline: 12 months from tax period end
Annual report providing aggregate tax jurisdiction-wide information relating to the global allocation of income, taxes paid, and indicators of economic activity.
BCL assists UAE entities in meeting notification requirements and preparing CbCR data for submission to the FTA or coordination with parent entity filings.
Certain entities may be exempt from specific documentation requirements, but ALL TAXPAYERS MUST COMPLY WITH THE ARM’S LENGTH PRINCIPLE.
Entities claiming Small Business Relief are exempt from TP documentation requirements
Entities not meeting revenue thresholds for Local/Master File
QFZPs must still adhere to ALP and maintain supporting documentation
BCL’s Expert Team ensure your Transfer Pricing files meet all FTA requirements and
provide robust audit defense.
BCL maintains subscriptions to leading global databases, ensuring access to
comprehensive, reliable comparable data for all transaction types.
A robust Benchmarking Study and Comparability Analysis are essential for applying the Arm’s Length Principle effectively. BCL Globiz deploys industry-leading databases and rigorous OECD-compliant methodologies to establish defensible transfer pricing positions for UAE businesses
Comprehensive review of industry dynamics, market conditions, and economic factors affecting the tested transaction.
Detailed mapping of controlled transactions, contractual terms and financial data extraction.
Characterisation of functions performed, assets employed, and risks assumed by each party to the transaction.
Systematic database search applying quantitative and qualitative screening criteria to identify reliable comparables.
Application of working capital and other adjustments to enhance comparability where differences exist.
Statistical analysis to establish arm's length range and determine appropriate pricing position.
Establishes defensible intercompany pricing using rigorously selected independent comparables.
Provides interquartile range analysis to reduce tax authority disputes and audit risk.
Serves as strong evidence for compliance, minimizing penalties and regulatory scrutiny.
No obligation.
Expert consultation with senior TP specialists.
The UAE’s definition of “Connected Persons” under Article 36 is broader than typical Related Party definitions globally. Without personal income tax in the UAE, the FTA mandates rigorous review of transactions with Connected Persons to prevent corporate tax base erosion through excessive payments disguised as salaries, bonuses, or other compensation.
Any Natural Person who directly or indirectly holds an ownership interest in the Taxable Person or exercises control over it, including its operations.
Any Director or Officer of the Taxable Person, including board members and key managerial pre (KMPs).
Any Related Party of the Owners, Directors, or Officers-including their relatives up to the fourth degree of kinship
Where the Taxoble Person is a partner in an. Unincorporated Partnership, any other perthes and their Related Parties qualify as Connected Persons.
Total payments or benefits to a Connected Person (and their Related Parties) exceeding this threshold triggers mandatory disclosure in the TP Disclosure Form.
Covered Compensation Types
Base Salary & Wages
Director Fees & Remuneration
Pension Contributions
End of Service Benefits
Performance Bonuses
Employee Stock Options (ESOP)
Housing & Transportation Allowances
Profit Sharing Arrangements
Our specialized salary benchmarking service ensures that compensation paid to owners, directors, KMPs, and their relatives meets the arm’s length standard required under UAE Corporate Tax Law.
Detailed mapping of job functions, reporting lines, decision-making authority, and scope of responsibilites.
Identification of comparable roles in the UAE market and GCC region based on industry, company size, and complexity.
Extraction of market salary data from specialized databases covering the UAE and regional markets.
Development of arm's length range using interquartile analysis and preparation of FTA-defensible documentation.
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Under the Article 28 of the UAE Corporate Tax Law issued by FTA, payments to Connected Persons are tax-deductible only if they satisfy the following conditions:
Compensation must reflect market value for comparable services
Expenditure must be incurred solely for business operations
Except specific cases like pension contributions under Article 33
Our comprehensive salary benchmarking deliverable includes:
A Related Party refers to an individual or entity with an established relationship with a business subject to UAE Corporate Tax. This relationship arises through ownership, control, or kinship-and differs significantly from IAS 24 definitions used in financial reporting.
Any Natural Person of Legal Entity directly or indirectly holding 50% or more ownership in the Taxable Person
Entities where the same person(s) directly or indirectly control 50% or more of both the Taxable Person and another entity
Relatives up to the fourth degree of kinship of an individual owner or controller of the Taxable Person
Any PE of the Taxable Person or any PE through which a Related Party conducts business
Partners in an Urincorporated Partnership where the Taxable Person is also a partner
Under the UAE TP Disclosure Form, all Taxable Persons must complete the Related Party schedule when specific thresholds are exceeded. Non-compliarice may result in penalties and increased FTA scrutiny.
Aggregate RP transactions triggering disclosure
Individual transaction category threshold
Required Disclosures per Transaction:
Intercompany services form the backbone of multinational operations. BCL provides rigorous benchmarking for all service arrangements.
Strategic, administrative, and corporate oversight services provided by parent or regional headquarters
Engineering, IT support, R&D assistance, and specialized technical advisory services
Centralized finance, HR, IT, procurement, and administrative functions
Brand development, advertising, distribution support, and sales enablement services
Complex manufacturing value chains require precise characterization and benchmarking based on functions, assets, and risks.
Manufacturing under license with limited IP ownership but significant operational autonomy
Entities owning IP, bearing market risk, and controlling key manufacturing decisions
Toll/contract manufacturing with limited risk and routine manufacturing functions
Product flows and distribution arrangements require robust comparable analysis based on distribution model and risk profile.
Distributors bearing inventory, credit, and market risks with full pricing authority
Distributors with reduced risks, often with guaranteed margins or return policies
Agents acting on behalf of principal without taking title to goods
Procurement hubs, logistics centers, and inventory management services
IP licensing requires specialized databases and valuation techniques to establish arm’s length royalty rates.
Licensing of brands names, trade names, and associated goodwill
Technology patents, manufacturing processes, and proprietary methods
Proprietary knowledge manufacturing know how and technical expertise
Complex intangibile arrangements including cost contribution agreements and IP migration structures.
Joint Development of intangibles with shared costs and benefits among participants
Fees for using group intangibles including software, databases, and proprietary systems
Allocation of centralized R&D costs to benefiting entities
Intangible transactions require specialized valuation expertise and access to royalty databases. BCL's IP specialists combine deep technical knowledge with industry-leading databases including RoyaltyStat, KtMINE, and Markables to establish globally defensible royalty rates and licensing terms.
Financial transactions require specialized analysis of credit ratings, loan terms, and market interest rates.
Intra-group lending arrangements including term loans and revolving facilities
Parent company guarantees and credit support arrangements
Notional and physical cash pooling arrangements with interest allocation
Centralized treasury and hedging services provided to group entities
BCL performs standalone credit rating analysis for intercompany borrowers using recognized methodologies. This ensures that intercompany Interest rates reflect the borrower's actual creditworthiness rather than benefiting from implicit parental support, unless such support is explicitly priced.
Our expert team deploys industry-leading databases and OECD-compliant methodologies to establish defensible arm’s length pricing for all your Related Party dealings.
Comprehensive review of all intercompany flows and contractual arrangements
Detailed FAR analysis to characterize entities and transactions accurately
Rigorous screening using global financial databases
Establishing interquartile range and FTA-ready documentation
Bureau van Dijk ORBIS
S&P Capital IQ
Bloomberg Terminal
RoyaltyStat
ktMINE
The definition of Related Parties under UAE Transfer Pricing regulations (Article 35, CT Law) differs from IAS 24 criteria used in financial statement disclosures. Businesses must conduct a separate assessment based on UAE TP rules rather than relying solely on accounting disclosures or global TP policies. BCL ensures your Related Party identification aligns with FTA requirements.
BCL’s transaction benchmarking service covers the entire spectrum of Related Party dealings. Our approach combines rigorous economic analysis with practical commercial insights to deliver defensible transfer pricing outcomes.
Connect with BCL Globiz for expert Transfer Pricing advisory tailored to your UAE business needs. Our team of specialists is ready to help you navigate Related Party & Connected Persons compliance, and all TP documentation requirements.
Authorized and registered with the Federal Tax Authority
Senior TP specialists with Big 4 and multinational experience
Efficient delivery without compromising quality
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