Transfer pricing should not be seen as a burden but as an opportunity
The UAE’s tax landscape is at a turning point. For the first time, businesses are preparing to file their corporate tax returns under a framework that places transfer pricing in the spotlight. With the September 30, 2025, deadline fast approaching, many companies are realising that this is more than just another compliance task ― it is a fundamental shift in how business structures are viewed.
At the core of these rules is the arm’s-length principle. In simple terms, it requires related-party transactions, whether between subsidiaries, group companies, or even dealings with shareholders and directors, to be priced just as they would be with an independent third party. For UAE businesses that have long operated in a tax-free environment, this marks a new era of accountability.
Perhaps the biggest test lies in the benchmarking study. Companies must now prove that their pricing is fair and in line with the market. Yet, finding reliable local data to support these studies can be difficult, particularly for niche industries. Recognising this, the Federal Tax Authority (FTA) advises businesses to start with domestic data wherever possible before expanding their search to regional or global benchmarks.
This isn’t just a matter of paperwork. With transfer pricing audits on the horizon, documentation becomes a company’s strongest defence. A well-prepared benchmarking report not only safeguards against penalties but also provides meaningful insights into where a business stands in the market.
The lesson for companies is clear: transfer pricing should not be seen as a burden but as an opportunity. Those who take a proactive approach, strengthening documentation, refining structures, and treating compliance as part of their strategy, will be better placed to thrive in the UAE’s evolving tax environment.
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