Transfer Pricing Due Diligence Services in UAE

Whether you are acquiring a company, attracting investors, restructuring a group, or preparing for tax audits, our due diligence services provide valuable insights that support informed business decisions and reduce potential tax exposure.

Our Transfer Pricing Due Diligence UAE services are designed to support businesses seeking Transfer Pricing Risk Assessment UAE, Transfer Pricing Compliance Review UAE, Related Party Transaction Review UAE, and broader UAE Corporate Tax Due Diligence support.

What is Transfer Pricing Due Diligence?

Transfer Pricing Due Diligence is a specialised review conducted to evaluate the transfer pricing practices, policies, and compliance status of a business. The objective is to identify potential risks, hidden tax liabilities, documentation gaps, and compliance issues related to transactions between related parties.

The process helps businesses understand whether their intercompany transactions comply with the Arm’s Length Principle and whether existing transfer pricing arrangements may create future tax risks.

Transfer pricing due diligence is commonly performed during:

• Mergers and acquisitions (M&A)
• Corporate restructuring
• Business valuations
• Private equity investments
• Joint ventures
• Group reorganisations
• Cross-border expansions
• Tax audit preparation

Why Transfer Pricing Due Diligence is Important

Transfer pricing issues discovered after a transaction can lead to substantial financial consequences, including:

• Corporate tax adjustments
• Penalties and interest charges
• Double taxation risks
• Regulatory investigations
• Reduced transaction value
• Increased compliance costs
• Reputational damage

A thorough transfer pricing review before completing a transaction helps stakeholders identify and quantify risks early, allowing them to negotiate protections, adjust valuations, or implement corrective actions.

Our Transfer Pricing Due Diligence Services

Review of Related-Party Transactions

We analyse all intercompany transactions, including:

• Sale and purchase of goods
• Management service charges
• Technical service fees
• Royalties and licensing arrangements
• Financing and loan transactions
• Cost-sharing arrangements
• Intellectual property transactions
• Business restructuring activities
• Shared employee and secondment arrangements
• Director and key management compensation
• Intra-group guarantees
• Regional headquarters service allocations
• IT, software, and support service arrangements

Our team evaluates whether these transactions comply with transfer pricing regulations and the Arm’s Length Principle.

Connected Person Compliance Review

Our due diligence assessments include a detailed review of Connected Person transactions such as:

• Director remuneration
• Owner compensation
• Management fees paid to shareholders
• Related-party service arrangements
• Payments to business owners and family members
• Compensation structures involving Connected Persons

We assess whether such payments satisfy UAE Corporate Tax requirements and are supported by appropriate commercial justification and transfer pricing documentation.

Transfer Pricing Documentation Assessment

We review existing documentation to determine compliance with UAE and OECD requirements, including:

• Local File
• Master File
• Transfer Pricing Reports
• Benchmarking Studies
• Country-by-Country Reporting (CbCR)
• Intercompany Agreements

We identify documentation gaps and areas requiring remediation.

Functional and Risk Analysis Review

Our specialists assess:

• Functions performed by group entities
• Assets employed
• Risks assumed by each party
• Economic substance of transactions

This analysis helps determine whether profit allocations are commercially justifiable and tax-compliant.

Benchmarking and Pricing Review

We evaluate existing transfer pricing methodologies and benchmark studies to determine whether pricing remains consistent with market conditions and arm’s length standards.

Our review includes:

• Selection of transfer pricing methods
• Comparable company analysis
• Profitability assessments
• Industry-specific benchmarking reviews

Tax Exposure Assessment

We identify and quantify potential transfer pricing risks, including:

• Understated taxable income
• Excessive deductions
• Non-arm’s length pricing
• Missing documentation
• Regulatory non-compliance

Our findings help buyers, investors, and management understand the financial impact of identified risks.

Intercompany Agreement Review

We review legal agreements governing related-party transactions to ensure consistency between:

• Contractual terms
• Actual business conduct
• Transfer pricing policies
• Tax reporting positions

Misalignment between agreements and business practices is a common source of transfer pricing disputes.

M&A Transfer Pricing Due Diligence

For acquisitions and mergers, we provide specialised assessments covering:

• Historical transfer pricing compliance
• Outstanding tax risks
• Audit exposure
• Potential post-acquisition adjustments
• Transaction structure implications

Our due diligence reports help buyers make informed investment decisions and negotiate transaction protections.

Pre-Audit Risk Assessment

We perform proactive reviews to identify areas that may attract scrutiny from tax authorities and recommend corrective actions before audits occur.

UAE Transfer Pricing Due Diligence Considerations

The UAE Corporate Tax regime has introduced comprehensive transfer pricing requirements that align with OECD standards. Businesses engaged in related-party transactions must demonstrate that their pricing arrangements comply with the Arm’s Length Principle.

Transfer pricing due diligence has become particularly important for:

• Multinational enterprise groups
• Family-owned business groups
• Free zone entities
• Regional headquarters
• Holding companies
• Cross-border service providers
• Investment and private equity structures

Failure to maintain adequate transfer pricing documentation may expose businesses to adjustments, penalties, and increased regulatory scrutiny.

UAE Transfer Pricing Documentation Requirements

As per the UAE Corporate Tax Transfer Pricing framework, businesses may be required to maintain transfer pricing documentation where:

• Aggregate Related Party Transactions exceed AED 40 million during the tax period; and
• Transactions within a specific category exceed AED 4 million.
• Certain Connected Person transactions may require disclosure where annual payments exceed AED 500,000.

Transfer pricing due diligence helps businesses assess whether existing documentation requirements have been met and identify potential compliance gaps before regulatory reviews.

Transfer Pricing Due Diligence for Free Zone Entities

Qualifying Free Zone Persons engaging in transactions with Related Parties or Connected Persons must comply with the Arm’s Length Principle under UAE Corporate Tax regulations.

Our due diligence reviews help Free Zone businesses identify transfer pricing risks that may affect Corporate Tax compliance, transfer pricing disclosures, transfer pricing documentation requirements, and ongoing regulatory obligations.

This review is particularly valuable for Free Zone companies undertaking group restructurings, attracting investors, entering new markets, or preparing for Federal Tax Authority reviews.

Preparing for FTA Transfer Pricing Reviews

The Federal Tax Authority may request transfer pricing documentation, disclosure forms, intercompany agreements, and supporting evidence during compliance reviews and audits.

Our due diligence process helps businesses:

• Identify audit exposure
• Address documentation deficiencies
• Strengthen transfer pricing governance
• Improve readiness for FTA enquiries
• Reduce potential adjustment risks
• Enhance compliance with UAE Corporate Tax requirements

Benefits of Our Transfer Pricing Due Diligence Services

Risk Identification Before Transactions

Discover potential transfer pricing issues before completing acquisitions, investments, or restructurings.

Improved Transaction Valuation

Understand the impact of transfer pricing risks on enterprise value and future tax liabilities.

Enhanced Regulatory Compliance

Ensure compliance with UAE Corporate Tax Law and OECD transfer pricing standards.

Reduced Tax Exposure

Identify opportunities to mitigate transfer pricing risks and avoid future disputes.

Better Negotiation Position

Use due diligence findings to negotiate warranties, indemnities, and purchase price adjustments.

Investor Confidence

Provide investors and stakeholders with confidence that transfer pricing risks have been thoroughly evaluated.

What You Will Receive

Our Transfer Pricing Due Diligence engagement typically includes:

• Transfer Pricing Risk Assessment Report
• Related Party Transaction Review
• Documentation Gap Analysis
• Intercompany Agreement Review
• Benchmarking Assessment Summary
• Tax Exposure Assessment
• Compliance Recommendations
• Risk Mitigation Action Plan
• Transaction Support Memorandum
• Executive Summary of Key Findings

Post-Due Diligence Remediation Support

Where transfer pricing risks are identified, our specialists assist businesses with:

• Documentation remediation
• Local File preparation
• Master File support
• Benchmarking updates
• Intercompany agreement revisions
• Transfer pricing policy enhancements
• Audit readiness support
• Transfer pricing disclosure support
• Ongoing compliance monitoring

This ensures that identified risks are not only reported but also effectively addressed through practical corrective actions.

Industries We Serve

We provide Transfer Pricing Due Diligence services across a wide range of industries, including:

• Trading and Distribution
• Manufacturing
• Technology and Software
• Financial Services
• Healthcare
• Construction
• Logistics and Supply Chain
• E-commerce
• Retail
• Professional Services
• Real Estate
• Energy and Utilities
• Family-Owned Business Groups
• Investment and Private Equity Structures

Why Choose German Fintax Consultancy?

German Fintax Consultancy combines international transfer pricing expertise with deep knowledge of UAE tax regulations. Our specialists assist businesses across various industries in identifying transfer pricing risks, strengthening compliance frameworks, and supporting strategic transactions.

Our approach is:

• Risk-focused
• Commercially practical
• OECD-aligned
• UAE Corporate Tax compliant
• Confidential and independent
• Tailored to transaction objectives

We provide clear, actionable recommendations that help clients manage transfer pricing risks and make informed business decisions.

As a trusted Transfer Pricing Consultant UAE, we combine technical expertise with practical commercial insight to help businesses navigate increasingly complex transfer pricing requirements while supporting transaction success and long-term compliance.

Need Transfer Pricing Due Diligence Support in UAE?

Whether you are evaluating an acquisition, preparing for investment, reviewing related-party transactions, assessing transfer pricing compliance risks, or preparing for a Federal Tax Authority review, our specialists can assist.

German Fintax Consultancy provides comprehensive Transfer Pricing Due Diligence UAE services, helping businesses identify tax exposures, strengthen compliance frameworks, and support strategic transactions with confidence.

Contact us today for a confidential assessment of your transfer pricing risks, documentation requirements, and compliance obligations.