Transfer Pricing Advisory Services.
Ensure strict compliance with the UAE's Corporate Tax Law. We help businesses structure and document related-party transactions in accordance with the Arm's Length Principle.
Transfer Pricing Services.
Delphi provides end-to-end transfer pricing compliance to help you mitigate risk and align your global business models.
Policy Design & Optimization
We develop robust transfer pricing policies aligned with your group's value creation strategy and UAE regulations.
Local & Master File Preparation
Comprehensive documentation to meet the mandatory requirements for businesses exceeding AED 200M revenue.
Benchmarking Studies
Using premier global databases to establish arm's length ranges for your related-party transactions.
Country-by-Country Reporting (CbCR)
Assistance with filing CbC reports for large multinational enterprise groups operating in the UAE.
Audit Defense & Representation
Strategic support and representation during FTA transfer pricing audits and inquiries.
Understanding Compliance Mandates.
Under Articles 34-36 of the UAE Corporate Tax Law, transactions between Related Parties and Connected Persons must comply with the Arm's Length Principle.
Businesses with revenues exceeding AED 200M, or part of a multinational group, must maintain a Local and Master File.
Details of related-party transactions must be submitted alongside the annual Corporate Tax Return.
Failure to provide transfer pricing documentation within 30 days of request can result in major administrative penalties.
Approved OECD & FTA Methods.
The UAE FTA strictly adheres to the OECD Guidelines. We assist in selecting and applying the most reliable method for your transactions.
CUP
Comparable Uncontrolled Price
Compares the price charged for property or services transferred in a controlled transaction to the price charged in a comparable uncontrolled transaction.
RPM
Resale Price Method
Evaluates whether the amount charged in a controlled transaction is arm's length by reference to the gross profit margin realized in comparable uncontrolled transactions.
CPM
Cost Plus Method
Evaluates the arm's length nature of a transaction by referencing the gross profit markup earned in comparable uncontrolled transactions.
TNMM
Transactional Net Margin
Examines the net profit margin relative to an appropriate base (e.g., costs, sales, assets) that a taxpayer realizes from a controlled transaction.
PSM
Profit Split Method
Identifies the combined profit to be split for the associated enterprises from a controlled transaction and then splits those profits.
Our Streamlined Process.
We handle the mapping, database searches, and documentation so your team can focus on operations.
Transaction Mapping
Identifying all related-party and connected-person transactions within your corporate group structure.
Functional Analysis (FAR)
Detailed profiling of the Functions performed, Assets employed, and Risks assumed by each related entity.
Benchmarking Studies
Performing economic analysis to determine the arm's length range using premier global databases.
File Drafting
Drafting the Master File, Local File, and Disclosure schedules in full compliance with UAE FTA regulations.
Frequently Asked Questions.
Ensure Your Compliance today.
Consult with our specialists to review your related-party transaction flows and establish robust Transfer Pricing files.
Book a Consultation