Transfer Pricing and Benchmarking
MHR helps businesses structure and document related party transactions in line with UAE Corporate Tax Law and OECD guidelines, keeping your transfer pricing policies defensible and audit ready.
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Transfer Pricing Services
Keeping Related Party Transactions at Arm's Length
Under the UAE Corporate Tax Law, businesses that transact with related parties and connected persons must price those transactions as if they were dealing with an independent party. MHR helps you apply the arm’s length principle correctly, preparing benchmarking studies, Local Files, Master Files, and disclosure forms that satisfy the Federal Tax Authority while reflecting how your business actually operates. Whether you run a group with cross-border related party dealings or a Qualifying Free Zone Person reviewing its structure, our team builds documentation that stands up to scrutiny and supports the pricing decisions you’ve already made.
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Compliance with Transfer Pricing Regulations !
Maintaining arm’s length pricing and proper documentation for related party transactions protects your business from disputes and penalties under UAE Corporate Tax Law. MHR offers professional guidance to keep your transfer pricing policies aligned with the latest FTA and OECD requirements.
FAQS
Frequently Asked Questions
Here are answers to some frequently asked questions about our Transfer Pricing and Benchmarking services, providing you with the information needed to better understand how we can support your business.
What is transfer pricing and why does it matter in the UAE?
Transfer pricing refers to the pricing of transactions between related parties and connected persons, such as the sale of goods, services, or financing. Under the UAE Corporate Tax Law, these transactions must be priced at arm’s length, the same terms independent parties would agree to, so profits are reported fairly rather than shifted between related entities.
Which businesses need to comply with UAE transfer pricing rules?
Any taxable person that transacts with related parties or connected persons falls within scope, including mainland companies, groups with cross-border dealings, and Free Zone entities such as Qualifying Free Zone Persons. Whether the obligation is disclosure, full documentation, or both depends on the size of the business and the value of its related party transactions.
What documentation is required for transfer pricing compliance?
Depending on transaction thresholds, businesses may need to file a disclosure form alongside their tax return and maintain a Local File and Master File documenting their related party dealings and pricing methods. Larger multinational groups may also carry Country-by-Country Reporting obligations.
How is the arm's length price determined?
The OECD Transfer Pricing Guidelines, which the UAE follows, set out five recognised methods for testing arm’s length pricing: the Comparable Uncontrolled Price method, Resale Price method, Cost Plus method, Transactional Net Margin Method, and Profit Split method. MHR carries out benchmarking studies to identify the most appropriate method and comparable data for your transactions.
What happens if my transfer pricing documentation isn't in order?
Insufficient or inconsistent documentation can lead to adjustments, penalties, and prolonged disputes with the Federal Tax Authority. Keeping benchmarking studies and supporting files up to date and ready for review is the best way to protect your business.