A transfer pricing model designed with intent

A defensible transfer pricing position is designed, not reconstructed. Intercompany pricing should follow from a clear understanding of where the group creates value — which entities perform the significant functions, own the key assets, and assume the material risks. Set on that basis it is coherent and defensible; set transaction by transaction without an underlying rationale, it is difficult to explain and easily challenged.

Our intercompany pricing advisory in the UAE is the design of that model and the specialist analysis behind it. We help businesses establish or refine how their intra-group transactions are priced, so the outcome reflects commercial reality, satisfies the arm's length principle, and can be articulated consistently. The work rests on rigorous economic analysis: a functional analysis establishes each party's profile and informs the selection of the most appropriate method under the OECD Guidelines.

How we help

Our capabilities span the design of the model, the specialist domains where pricing is most technical, and the readiness and defence of the position as the regime matures.

Strategy, policy and structuring

  • Transfer pricing planning and policy design — designing how the group prices each category of intercompany transaction, on a consistent, defensible basis. The policy formulated here is recorded and evidenced on the Transfer Pricing Policy page under Documentation.
  • Value-chain and supply-chain structuring (DEMPE) — aligning pricing with where value is created, applying the DEMPE framework to intangibles so returns follow the functions and risks that generate them.
  • Business restructuring and exit-charge analysis — advising on the transfer pricing consequences of reorganisations, centralisations and changes in operating model, including exit charges where functions, assets or risks move between entities.
Specialist pricing domains
  • Intra-group financing and treasury pricing — pricing loans, guarantees, cash pooling and other treasury arrangements at arm's length, where the UAE's interest-limitation rules and the OECD's financial-transactions guidance intersect.
  • Free Zone and QFZP transfer pricing — designing arrangements for free zone entities, where the arm's length outcome can bear directly on whether a Qualifying Free Zone Person retains its 0% status.
  • Transfer pricing, customs and e-invoicing — reconciling the transfer price with customs valuation and the UAE's e-invoicing framework, delivered with our Indirect Tax team.
Certainty, readiness and defence
  • Controversy, audit defence and APAs — supporting the position when questioned, and securing certainty in advance, including Advance Pricing Agreement strategy and pre-filing positioning with the FTA.
  • Health check and readiness diagnostic — a focused review of how ready the current model and its documentation are for scrutiny. A fuller diagnostic of exposure is provided by our Risk Assessment service.
  • Audit-readiness review — testing whether the position, as designed and documented, would withstand an FTA enquiry today.
  • Policy refresh for the second and third filing cycles — revisiting first-cycle positions in light of subsequent Public Clarifications and FTA practice.
When advisory support is most valuable
  • New intra-group transactions are being established and should be priced correctly from the outset.
  • A review or a filing has indicated that existing pricing requires redesign, not merely documentation.
  • The group is restructuring, centralising functions, or reshaping its supply chain.
  • Positions taken in the first filing cycle warrant a considered refresh in light of evolving FTA guidance.

The UAE position

  • Framework — Arm's length principle — Articles 34 to 36, Federal Decree-Law No. 47 of 2022
  • Methodology — Functional analysis, DEMPE and method selection under the OECD Transfer Pricing Guidelines and the FTA TP Guide
  • Deliverable — A designed transfer pricing policy and operating model, ready to be documented