Transfer Pricing

Protect your business.Price with precision.

Build defensible, OECD-compliant TP frameworks. Risk assessments, benchmarking, documentation, and FTA audit defence.

10+
Years experience: OECD
Aligned framework: ALP
Arm's length principle: CbCR
Country-by-country

Overview

Part of our Taxation practice.

Transfer Pricing has become one of the most scrutinised areas of tax compliance globally — and with the UAE's adoption of OECD-aligned Transfer Pricing regulations under the Corporate Tax Law, it is now equally central to compliance in the Emirates.

At its core, Transfer Pricing governs the pricing of transactions between related parties and connected persons. The arm's length principle requires that these transactions be priced as they would be between independent parties dealing at market value.

Where the Federal Tax Authority determines that related-party transactions are not at arm's length, it has the authority to make a Transfer Pricing adjustment — recalculating taxable income and imposing significant additional tax and penalties.

MNV Associates' Transfer Pricing specialists combine deep technical knowledge with practical commercial understanding to help you build a defensible, OECD-compliant TP framework.

Our Transfer Pricing services

Defensible TP frameworks that withstand regulatory scrutiny.

Impact Assessment & Structuring

Quantitative and qualitative TP risk assessment across your entity or group
Transaction mapping and intercompany flow analysis
Tax grouping considerations and TP implications
Functional analysis and value chain assessment

TP Policy & Compliance

Transfer Pricing policy design and implementation
Benchmarking analysis using OECD-approved methodologies
Local file, master file, and country-by-country (CbCR) report preparation
TP documentation in line with FTA and OECD requirements
FTA audit support and TP dispute resolution

“Transfer Pricing is not merely a documentation exercise — it is a strategic discipline that protects your tax position and demonstrates the commercial integrity of your group's intercompany arrangements.”

MNV Associates

Our process