Transfer Pricing Policy Drafting and Review Services in UAE

What is a Transfer Pricing Policy?

A transfer pricing policy is an internal document that outlines how related-party transactions within a corporate group are priced. It serves as a guiding framework for determining, implementing, and monitoring intercompany pricing arrangements in accordance with the arm’s length principle.

A well-structured transfer pricing policy helps organisations:

• Ensure compliance with transfer pricing regulations
• Standardise intercompany pricing practices
• Reduce tax and audit risks
• Support transfer pricing documentation requirements
• Improve consistency across jurisdictions
• Enhance corporate governance and tax transparency

UAE Transfer Pricing Applicability Assessment

Before drafting or reviewing a Transfer Pricing Policy, businesses should assess whether they fall within UAE Transfer Pricing documentation and disclosure requirements.

Under current UAE Corporate Tax regulations, documentation obligations may arise where:

• Aggregate Related Party Transactions exceed AED 40 million during the tax period
• A specific category of Related Party Transactions exceeds AED 4 million during the tax period
• Connected Person Transactions exceed AED 500,000 during the tax period
• Transfer Pricing Disclosure obligations apply

Our specialists assess whether your business falls within UAE Transfer Pricing compliance requirements and whether a formal Transfer Pricing Policy should be established.

Does Your Business Need a Transfer Pricing Policy?

You may require a formal Transfer Pricing Policy if:

✓ You operate multiple group entities

✓ You charge or receive management fees

✓ You provide intercompany services

✓ You have intercompany loans or financing arrangements

✓ You own or share intellectual property

✓ You operate in a UAE Free Zone

✓ You have Related Party or Connected Person transactions

✓ You are preparing Transfer Pricing Documentation, Local Files, or Master Files

A formal Transfer Pricing Policy helps establish consistency, improve governance, and strengthen audit readiness.

Our Transfer Pricing Policy Drafting Services

We assist businesses in developing tailored transfer pricing policies that reflect their operational realities, industry practices, and regulatory obligations.

Our services include:

Functional and Risk Analysis

We assess the functions performed, assets utilised, and risks assumed by each group entity to establish an appropriate transfer pricing framework.

Related Party and Connected Person Assessment

An effective Transfer Pricing Policy begins with identifying all relevant Related Party and Connected Person relationships.

Our specialists assist with:

• Related Party identification
• Connected Person analysis
• Shareholding reviews
• Family-owned business structure analysis
• Common control assessments
• Cross-border ownership reviews

This assessment forms the foundation of a compliant Transfer Pricing Policy.

Intercompany Transaction Mapping

Our experts identify and categorise all related-party transactions, including:

• Management services
• Technical services
• Shared services
• Intellectual property arrangements
• Financing transactions
• Distribution and procurement activities
• Cost-sharing arrangements

Selection of Transfer Pricing Methodologies

We determine the most appropriate transfer pricing methods based on OECD Guidelines and applicable local regulations.

Policy Documentation Development

We prepare comprehensive transfer pricing policies covering:

• Pricing methodologies
• Profit allocation mechanisms
• Cost allocation approaches
• Benchmarking considerations
• Documentation requirements
• Governance and compliance procedures

Alignment with OECD and Local Regulations

Our policies are designed to align with:

• OECD Transfer Pricing Guidelines
• UAE Transfer Pricing Regulations
• BEPS Action Plans
• Country-specific transfer pricing requirements
• Global minimum tax considerations where applicable

Transfer Pricing Policies for Free Zone Businesses

Businesses operating within UAE Free Zones must ensure that their Related Party and Connected Person transactions comply with Transfer Pricing requirements while maintaining eligibility for applicable Free Zone Corporate Tax benefits.

Our services include:

• Transfer Pricing Policy development for Free Zone Persons
• Related Party transaction reviews
• Qualifying Free Zone Person considerations
• Intercompany pricing framework design
• Transfer Pricing compliance assessments

Transfer Pricing Governance Framework

A strong Transfer Pricing Policy should be supported by robust governance processes.

We help businesses establish:

• Pricing approval procedures
• Documentation ownership responsibilities
• Compliance monitoring frameworks
• Policy review mechanisms
• Reporting and escalation procedures
• Transfer Pricing governance controls

This strengthens accountability and supports long-term compliance.

Intercompany Agreement Review and Alignment

Transfer Pricing Policies should be consistent with the legal agreements governing intercompany transactions.

We review and align policies with:

• Management Service Agreements
• Intercompany Loan Agreements
• Distribution Agreements
• Licensing Agreements
• Cost Sharing Agreements
• Royalty Agreements
• Shared Service Agreements

This helps reduce inconsistencies that may attract regulatory scrutiny.

Transfer Pricing Policy Implementation Support

A well-drafted policy must be effectively implemented throughout the organisation.

Our implementation services include:

• Finance team training
• Internal policy roll-out
• Transaction monitoring procedures
• Governance framework implementation
• Internal control recommendations
• Operational alignment support

Transfer Pricing Policy Review Services

For businesses with existing transfer pricing policies, we conduct detailed reviews to identify gaps, inconsistencies, and compliance risks.

Our review process includes:

Compliance Assessment

Evaluation of the policy against current transfer pricing regulations and international standards.

Risk Identification

Identification of areas that may expose the business to:

• Tax adjustments
• Penalties
• Double taxation
• Audit challenges
• Documentation deficiencies

Policy Effectiveness Analysis

Assessment of whether current pricing methodologies accurately reflect the economic substance of transactions.

Recommendations and Enhancements

We provide practical recommendations to strengthen policy effectiveness and improve compliance.

Transfer Pricing Policy Health Check

Our Policy Health Check service provides a focused review of existing Transfer Pricing Policies to identify:

• Compliance gaps
• Outdated methodologies
• Documentation weaknesses
• Audit vulnerabilities
• Governance deficiencies
• Policy inconsistencies

This service is ideal for businesses seeking assurance before a tax audit or annual compliance cycle.

Why Transfer Pricing Policy Reviews Are Important

Transfer pricing regulations continue to change globally. Policies that were compliant a few years ago may no longer adequately address current requirements.

Regular reviews help businesses:

• Adapt to regulatory changes
• Address evolving business models
• Reflect new intercompany transactions
• Improve audit preparedness
• Reduce exposure to tax disputes

Our Approach

At German Fintax Consultancy, we follow a structured methodology:

1. Understanding Your Business

We gain a detailed understanding of your organisational structure, business operations, and intercompany arrangements.

2. Risk and Compliance Assessment

We evaluate existing practices and identify compliance risks.

3. Policy Design or Review

Our specialists draft or review transfer pricing policies tailored to your business needs.

4. Documentation and Implementation Support

We provide practical guidance for implementation and ongoing compliance.

5. Continuous Monitoring Support

We assist businesses in updating policies as regulations and business operations evolve.

Industries We Serve

We support transfer pricing policy development and review for businesses across various sectors, including:

• Manufacturing
• Distribution and Trading
• Technology
• E-commerce
• Financial Services
• Healthcare
• Logistics
• Energy
• Professional Services
• Consumer Goods

Why Choose German Fintax Consultancy?

Specialised Transfer Pricing Expertise

Our team possesses extensive experience in international transfer pricing regulations and OECD standards.

Tailored Solutions

We develop customised policies that reflect the specific commercial realities of your business.

Regulatory Compliance Focus

We help ensure alignment with local and international transfer pricing requirements.

Practical Implementation Support

Our recommendations are designed to be practical, operationally feasible, and sustainable.

Risk Mitigation Approach

We focus on reducing exposure to transfer pricing disputes, penalties, and tax adjustments.

Build a Robust Transfer Pricing Policy for Long-Term Compliance

Whether you are a multinational enterprise, family-owned group, Free Zone business, or UAE corporate entity, German Fintax Consultancy can help you develop and maintain a Transfer Pricing Policy that aligns with UAE Corporate Tax requirements, OECD Guidelines, and your commercial objectives.

Contact our Transfer Pricing specialists today for a Transfer Pricing Policy Assessment and discover how a well-designed policy can strengthen compliance, reduce tax risks, improve governance, enhance audit readiness, and support sustainable business growth.

Strengthen Your Transfer Pricing Compliance

A robust transfer pricing policy is essential for managing tax risks, maintaining regulatory compliance, and supporting sustainable international growth. German Fintax Consultancy helps businesses develop and maintain practical, defensible transfer pricing policies that align with global standards and local requirements.

Contact German Fintax Consultancy today to discuss your transfer pricing policy drafting and review requirements.