Transfer Pricing

Ensuring compliance & optimizing intercompany transactions

Baker Tilly professionals have a long-standing presence in the UAE market, bringing deep understanding of local business dynamics and regulatory requirements. As part of the Baker Tilly International network, we combine global insights with local expertise to deliver Transfer Pricing solutions that are practical, innovative, and future-ready.

By combining global best practices with deep local insight, we help businesses establish frameworks that are practical, robust, and future-ready. 

Our Transfer Pricing (‘TP’) Offerings

Comprehensive TP Services Tailored for Your Business

1. Compliance & Documentation
   • Local File & Master File preparation- comprehensive TP documentation aligned with OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2020) (‘OECD Guidelines’) and UAE Corporate Tax Transfer Pricing Guide issued by the Federal Tax Authority on 23 October 2023 (‘UAE Transfer Pricing Guide’).
   • TP disclosures- accurate, timely reporting for seamless compliance.
   • Country-by-Country Reporting (CbCR) preparation and disclosure that aligns with OECD Guidelines and UAE requirements.
2. Planning & Policy Design
   • Value chain analysis- map key functions, assets and risks to align TP policies with actual business substance.
   • Impact assessment- evaluate your organization’s readiness for UAE TP compliance and recommend most appropriate methodology to ensure alignment with regulations.
   • Intercompany Pricing Framework- develop consistent pricing models for all intercompany transactions that meet OECD Guidelines and UAE Transfer Pricing Guide.
   • Scenario Modeling & Restructuring Advisory- Evaluate TP impact of business changes (e.g mergers, supply chain shifts) and optimize profit allocation strategies.
3. Benchmarking & Economic Analysis
   • Comparable Searches: Precision driven benchmarks for compliant pricing.
   • Industry Insights: Sector-specific analysis that reflects real market dynamics.
   • Adaptive benchmarking- stay aligned with evolving market conditions.
4. Audit & Dispute Resolution
   • TP audit support- end to end assistance during TP audits to safeguard compliance and minimize risk.
   • Representation in tax authority negotiations- experienced advocacy to resolve issues efficiently.
   • MAP (Mutual Agreement Procedure) assistance- guidance and support in cross border tax dispute resolution through MAP for fair and timely outcomes.
5. Advance Pricing Agreements (‘APAs’)
   • Feasibility Review- assess and identify transactions suited for APAs.
   • End-to-End Support- comprehensive support throughout the APA process- From application to final agreement.
   • Strategic Certainty- secure agreed pricing for multiple years, ensuring predictability and compliance.

Ensure compliance & optimize your transfer pricing strategy

Transfer pricing regulations require businesses to maintain accurate documentation and align intercompany transactions with regulatory standards. At Baker Tilly, we help organizations achieve compliance while minimizing tax risks and enhancing profitability.

Ready to optimize your Transfer Pricing strategy? Let’s talk