KPMG’s Transfer Pricing team provides a comprehensive range of Transfer Pricing services in the United Arab Emirates.

We help our clients navigate all aspects of their Transfer Pricing requirements, from transformational advisory projects involving complete Transfer Pricing policy and implementation, through local and global Transfer Pricing documentation and compliance engagements, to Transfer Pricing opportunity and risk assessments, due diligence and audit assistance.

With in depth knowledge of UAE TP regulations grounded in Transfer Pricing principles set out the OECD Guidelines, our TP specialists bring strong practical local, regional and global experience, as well industry specific experience and expertise in areas such as financial services and transactions.

By combining technical expertise with innovative digital solutions, KPMG helps organizations manage risk, enhance transparency, and embed sustainable TP processes and solutions.

Expert team

Seasoned professionals with deep UAE tax expertise

Innovative solutions

Cutting-edge approaches to complex Tax challenges

Trusted partner

Reliable guidance for your business growth

Our services

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TP opportunity / Risk assessment

Review TP policies to ensure alignment with the arm’s length principle and identify potential TP risks and optimization opportunities.

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TP compliance

Preparation and management of TP documentation including Local Files, Master Files, disclosure forms, and CbC reporting.

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Other TP projects

Support with APAs, business restructuring, TP due diligence, connected person benchmarking, and tax provisioning.

Reviewing existing TP policies and intercompany transactions to assess alignment with the arm’s length principle and domestic TP regulations.
Evaluating pricing methodologies, documentation frameworks, and operational practices applied across the group.
Identifying potential TP opportunities, risks, gaps in documentation, and areas of exposure to tax authority scrutiny.
Providing practical recommendations to strengthen TP compliance and improving the group’s overall TP framework.

Preparing Local Files and Master Files in accordance with OECD guidelines and local TP regulations.
Assisting with preparation of TP disclosure forms and supporting documentation.
Supporting preparation and filing of Country-by-Country (CbC) notifications and reports where applicable.
Managing end-to-end TP documentation requirements across multiple jurisdictions.

Assisting with Advance Pricing Agreements (APAs) and related discussions with tax authorities.
Supporting business restructuring projects, including TP implications.
Conducting connected person remuneration benchmarking analyses.
Providing TP support for M&A due diligence, financing transactions, and tax provisioning.

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TP policy design

Design and structure TP policies, including group TP models, new entity frameworks, and pricing of intercompany transactions.

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Comprehensive TP support for UAE groups

End to end advisory and compliance support for UAE headquartered groups.

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TP technology / automation

Implementation of technology tools to streamline TP documentation, data management, and compliance workflows.

Assisting in structuring and designing TP policies aligned with the group’s operating model and value chain.
Developing group-wide TP models to support consistent profit allocation across jurisdictions.
Designing pricing frameworks for intercompany transactions such as management services, distribution, financing, and IP licensing.
Supporting development of TP frameworks for new entities, new business lines, or geographic expansion.

Comprehensive TP support for multinational enterprise Groups headquartered in the UAE:
Design of holistic TP policies including involvement of local KPMG offices, where required.
Assistance with specialized projects (e.g., head office management fee framework design and implementation).
Full suite of compliances services, including TP disclosure forms, Local File, Master File, CbC notifications and reports in the UAE and globally.

Implementing technology solutions to streamline TP documentation and compliance processes.
Supporting the use of digital platforms for workflow management, data sharing, and documentation tracking.
Facilitating collaboration between tax, finance, and operational teams through centralized tools.
Improving efficiency and standardization in TP documentation preparation and monitoring.

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TP policy implementation

Support implementation of TP policies through benchmarking studies, documentation, and intercompany agreements.

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TP audit and dispute support

Assistance during tax audits, including responding to authority queries and obtaining private clarifications.

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Specialized TP capabilities

Specialized TP support for complex sectors such as financial services, sovereign wealth funds, and oil and gas.

Conducting benchmarking studies to determine appropriate arm’s length pricing ranges.
Supporting implementation of TP policies across the organization.
Preparing and reviewing intercompany agreements and TP documentation to reflect the group’s policies.
Establishing internal processes and workflows to ensure consistent application of TP policies.

Supporting clients during TP audits and tax authority reviews.
Assisting in preparing responses to tax authority queries and information requests.
Providing support with Mutual Agreement Procedure (MAP) claims.
Assisting in obtaining private clarifications or rulings from tax authorities on TP matters.

Providing TP advisory services for complex sectors and transactions.
Supporting clients in industries such as financial services, sovereign wealth funds, family businesses, real estate, and oil and gas.
Addressing sector-specific pricing considerations and regulatory requirements.
Assisting with analysis of complex transactions and value chain structures.