Transfer Pricing Advisory Built Around Business Reality
MGKM Advisors supports UAE businesses and groups with transfer pricing analysis, documentation, benchmarking, related party transaction reviews and operational transfer pricing — with a focus on functional analysis, financial outcomes and practical implementation.
Transfer Pricing should reflect how the business actually operates
UAE Transfer Pricing requires businesses to support related party and connected person arrangements under the arm’s length principle. The analysis must consider functions performed, risks assumed, assets used, financial outcomes and supporting documentation.
MGKM approaches Transfer Pricing as more than a Local File or benchmarking exercise. We review the business model, transaction flow, contractual terms and actual implementation so that pricing positions are coherent and defensible.
Why It Matters
Transfer Pricing risk often appears when documents and reality do not align
How MGKM Helps
Transfer Pricing support that connects analysis, documentation and implementation
We support UAE businesses with related party transaction analysis, functional reviews, benchmarking, documentation, connected person assessments, and operational transfer pricing considerations.
- Transfer pricing risk assessments and readiness reviews
- Related party transaction analysis and arm’s length support
- Connected person remuneration and benefit assessments
- Functional, asset and risk analysis for controlled transactions
- UAE Local File, Master File and documentation support
- Transfer Pricing Disclosure Form support
- Benchmarking studies, economic analysis and comparable company reviews
- Intercompany pricing policy design and review
- Intercompany agreement review from a Transfer Pricing perspective
- Operational transfer pricing review, including policy implementation, invoicing, accounting, and year-end alignment.
- Transaction-specific analysis for services, financing, guarantees, royalties, distribution and management charges
- Support on FTA enquiries, transfer pricing reviews and documentation requests
Beyond documentation: aligning Transfer Pricing policy with practice
Policy
Alignment
Reviewing whether the documented policy reflects the business model and is capable of being implemented in practice.
Invoicing & Accounting
Assessing whether invoices, accounting entries and cost allocations support the intended intercompany pricing position.
Year-End Adjustments
Considering whether results require review or adjustment to align with the intended arm’s length outcome.
Monitoring & Controls
Helping businesses establish review processes so Transfer Pricing is monitored during the year, not only at documentation stage.
Different transactions require different Transfer Pricing analysis
1.
Intra-Group Services
Reviewing management fees, support services, shared cost arrangements and low value-adding services with reference to benefit tests, allocation methodologies and supporting documentation.
2.
Goods & Trading Transactions
Analysing distribution models, resale arrangements, margins, market roles and risks assumed by each related party.
3.
Intangibles & Royalties
Considering ownership, use of intellectual property, brand charges, licence arrangements and value creation.
4.
Financing Transactions
Reviewing intercompany loans, interest rates, guarantees, cash pooling and financing flows from an arm’s length perspective.
5.
Business Restructuring
Assessing changes in functions, risks, assets, contractual arrangements and profit allocation following group reorganisations.
6.
Connected Persons & Management Remuneration
Supporting remuneration and benefit positions through role analysis, market references, governance considerations and documentation of responsibilities performed.
Why MGKM
Transfer Pricing advisory with economic analysis and financial understanding
Business Model Review
We start with how the group operates, how value is created and how the parties interact commercially.
Economic Analysis
We support pricing positions through method selection, benchmarking and assessment of financial outcomes.
Documentation Discipline
We help prepare clear documentation that explains the transaction, analysis and basis for the position taken.
Implementation Focus
We consider whether policies are reflected in agreements, invoices, accounting records and year-end results.
Transfer Pricing FAQ
Questions groups often raise when pricing related party transactions
No. Documentation is important, but Transfer Pricing also requires analysis of the business model, functions, risks, assets, pricing methods, financial outcomes and the way transactions are implemented.
Functional analysis identifies what each party does, what risks it assumes and what assets it uses. This analysis drives method selection, benchmarking and the overall arm’s length support.
Yes. UAE Transfer Pricing rules can apply to domestic related party transactions as well as cross-border arrangements, depending on the facts and reporting requirements.
Connected person payments should be supported by role analysis, responsibilities performed, market references where appropriate, governance records and evidence that the payment is reasonable for the services or functions provided.
Operational transfer pricing focuses on whether pricing policies are reflected in actual invoicing, accounting entries, cost allocations, year-end adjustments and monitoring processes.
Transfer Pricing should be reviewed when a business enters new related party transactions, changes pricing models, restructures operations, adds financing arrangements, introduces service charges or prepares Corporate Tax documentation.
Speak to MGKM
Need support with related party transactions or Transfer Pricing documentation?
Whether you require a Local File, benchmarking study, connected person analysis, TP health check or operational transfer pricing review, MGKM helps align the analysis, documentation and implementation behind the position.