Charges follow historic practice
The rate or allocation has continued without a current analysis of benefits, functions, costs or market support.
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UAE Transfer Pricing / Policy & Documentation
Put the pricing logic, commercial termsand actual conduct on the same page.
We document how an intercompany arrangement is meant to operate, why the selected pricing method fits and how finance should apply it. The result connects the policy to agreements, invoices, operational evidence and the numbers recorded in the accounts.
Transaction-specificBuilt around the arrangement, not a generic group policy
Function-ledActivities, assets and controlled risks drive the method
ImplementableCalculation and monitoring steps are defined
When this service fits
Choose it for a defined business need.
Use this service when the business understands the transaction population but the pricing rule, written support or implementation process is incomplete.
Agreement and conduct differ
The written terms do not match who performs the work, controls the risks, owns the assets or bears the costs.
A new policy must be implemented
Management needs a practical calculation, invoicing and year-end true-up process—not only a technical conclusion.
Existing documents need an update
The business model, entities, transaction values or economic conditions have materially changed since the policy was prepared.
How the engagement moves
Four stages. A defined output at every stage.
We first delineate the actual arrangement. Method selection and documentation follow from that analysis, rather than being chosen to produce a preferred number.
01Stage 01
Confirm the arrangement
Review the commercial purpose, parties, written terms, invoicing flow and actual conduct for the transaction being documented.
Stage outputDelineated transaction statement
02Stage 02
Perform the functional analysis
Identify economically significant functions, assets and risks, including which people make and control key decisions.
Stage outputFunctions, assets and risks analysis
03Stage 03
Select and document the method
Assess the available UAE-recognised methods, data and tested-party considerations, then record the selected approach and assumptions.
Stage outputPricing-method rationale
04Stage 04
Design implementation controls
Define the calculation base, allocation keys, invoice support, review frequency, true-up process and owners within finance.
Stage outputImplementation control checklist
Defined deliverables
What management receives.
The exact documents depend on the transaction. A management-service arrangement should not receive the same pack as a loan or distribution model.
Transaction policy memo
Commercial rationale, delineated arrangement, pricing approach, assumptions and the decision rules finance must apply.
Functional analysis
An evidence-based account of each party's activities, assets, decision-making and risk control.
Calculation and support schedule
Defined cost pools, allocation keys, rates, tested results or other transaction-specific computation logic.
Implementation checklist
Actions needed to align agreements, invoicing, accounting codes, evidence retention and periodic monitoring.
Policy design principle
A written policy does not override what the parties actually do.
Transfer Pricing documentation should reflect the economically significant conduct of the parties. If the people, decision-making, risks or financial outcome differ from the paper terms, the policy needs to address the facts rather than simply restate the agreement.
Federal Tax Authority — Transfer Pricing Guide (CTGTP1)Delineate the actual transaction
Start with contractual terms, conduct, economic circumstances and the commercial objective.
Identify value and risk control
Record who performs key work, uses assets, makes decisions and has the capability to manage risks.
Choose the most appropriate method
The method should fit the transaction and reliable information available; there is no universal default.
Reassess material policies
The FTA guide expects policies and supporting documentation to remain contemporaneous and be reviewed regularly.
Records to begin
Start with the evidence that creates the position.
Interviews are normally required because agreements and accounting records do not, by themselves, show how functions and risks are controlled.
- Existing intercompany agreements and policy documents
- Transaction invoices and calculation workpapers
- Department and management interviews
- Process maps, approval records and responsibility matrices
- Segmented financial information where available
- Budgets, forecasts and year-end true-up records
- Evidence of service benefits or allocation drivers
- Prior benchmarking or external pricing information
Questions before you engage
Clear answers about this scope.
These answers explain the service boundary. The final treatment and engagement plan depend on the entity, period, records and current UAE requirements.
Is an intercompany agreement enough?
No. The agreement is one part of the evidence. It should align with actual conduct, benefits, functions, risk control, invoices and the recorded financial result.
Which pricing method will be used?
We select the method after delineating the transaction and testing the reliability of available internal and external data. The answer can differ by transaction.
Can one policy cover every group entity?
A group framework can provide consistency, but material local differences in functions, risks, markets or transaction terms still need to be addressed.
Will you help finance apply the policy?
Yes. The deliverables can define calculation inputs, allocation keys, invoice evidence, review points and the year-end true-up process.
How often should the policy be reviewed?
At least when the business model, parties, terms or market conditions change materially. The continuing review frequency is agreed according to the transaction and available data.
Related services
Move to the service that matches the next requirement.
Each page has its own defined purpose. Use the current service for the work described here, or choose another service when the business need changes.
Contact Us
Discuss a TP Policy Document the commercial reality before it becomes a filing problem.
Share the transaction type, parties, existing agreement and current calculation so we can define the documentation scope.