Transfer Pricing

As businesses expand across jurisdictions, intercompany transactions are becoming increasingly complex and heavily scrutinized by tax authorities. Regulatory frameworks across the UAE and globally now expect businesses to demonstrate that pricing arrangements reflect commercial reality, economic substance, and operational conduct.

A poorly designed Transfer Pricing model can create inconsistencies between business operations, financial outcomes, and tax positions — increasing exposure to audits, disputes, and regulatory adjustments.

SBC helps businesses build operationally aligned and commercially defensible Transfer Pricing frameworks that support compliance while remaining practical for implementation across finance, legal, and operational functions.

Transfer Pricing policies should not exist only in documentation — they should function effectively within the realities of the business. We help multinational groups, regional businesses, and growing enterprises design and operationalise Transfer Pricing frameworks that align with their value chain, operating model, and commercial objectives.

Our approach combines technical analysis, economic modelling, and practical implementation support to ensure that intercompany arrangements are aligned with OECD Guidelines, UAE Transfer Pricing Regulations, and evolving global tax expectations.

From FAR analysis and DEMPE reviews to pricing model development and operational implementation, we support businesses in creating Transfer Pricing structures that are scalable, defensible, and commercially sustainable.

Benchmarking has become one of the most scrutinized areas within Transfer Pricing compliance. Regulatory authorities increasingly expect businesses to support intercompany pricing through objective market evidence and reliable economic analysis.

Outdated or poorly prepared benchmarking studies can expose businesses to pricing adjustments, disputes, and challenges during audits. As financial data, market conditions, and industry performance evolve, businesses must ensure that benchmarking frameworks remain current, defensible, and aligned with operational realities.

SBC helps businesses develop robust benchmarking studies that support arm's length outcomes while strengthening audit readiness and long-term compliance.

A defensible benchmarking study goes beyond identifying comparable companies — it requires careful evaluation of economic conditions, functional comparability, and market reliability.

We assist businesses in preparing benchmarking analyses aligned with OECD principles and UAE Transfer Pricing expectations through structured screening methodologies, detailed comparability analysis, and economic reviews.

Our approach focuses on building benchmarking frameworks that are technically sound, commercially relevant, and capable of withstanding regulatory scrutiny across jurisdictions.

Transfer Pricing compliance obligations in the UAE are evolving rapidly under the Corporate Tax regime. Businesses are now expected to maintain structured documentation frameworks, accurately disclose related-party arrangements, and demonstrate that intercompany transactions satisfy arm's length requirements.

Regulators increasingly assess not only whether documentation exists, but whether it is operationally consistent, technically robust, and aligned with financial reporting positions.

SBC helps businesses establish defensible compliance frameworks that support both immediate reporting requirements and long-term audit preparedness.

Transfer Pricing compliance now sits at the intersection of governance, reporting, and regulatory risk management. We support businesses in preparing structured TP documentation aligned with OECD standards and UAE Transfer Pricing Regulations.

From Disclosure Forms and related-party mapping to Local File and Master File preparation, our approach focuses on building documentation that is commercially aligned, technically defensible, and ready for regulatory scrutiny.

Our support extends beyond documentation drafting into implementation alignment, audit preparedness, and ongoing compliance management.

As Transfer Pricing scrutiny increases globally, businesses are seeking greater certainty over pricing positions and cross-border tax outcomes. Advance Pricing Arrangements (APAs) provide a structured mechanism to reduce uncertainty, mitigate dispute exposure, and establish agreed pricing methodologies with tax authorities in advance.

For businesses with significant intercompany transactions, complex structures, or high-risk arrangements, APAs can provide long-term stability and stronger regulatory confidence.

SBC supports businesses throughout the APA lifecycle — from feasibility assessment to application management and ongoing monitoring.

Advance Pricing Arrangements are increasingly becoming an important risk management tool for multinational groups operating across multiple jurisdictions.

We assist businesses in evaluating APA suitability, preparing defensible applications, and managing authority interactions through a structured and commercially focused approach.

Our support combines economic analysis, technical documentation, and practical implementation guidance to help businesses navigate complex APA processes effectively.

Regulators increasingly expect intercompany agreements to reflect operational reality, commercial substance, and actual business conduct. Agreements that are inconsistent with Transfer Pricing documentation or operational execution can create significant audit exposure and weaken pricing defensibility.

Businesses today require intercompany agreements that not only satisfy legal requirements but also align with Transfer Pricing policies, financial outcomes, and commercial arrangements.

SBC helps businesses build agreement frameworks that support stronger governance, regulatory consistency, and operational alignment.

Intercompany agreements are a critical component of Transfer Pricing governance and regulatory defence. We assist businesses in drafting, reviewing, and aligning agreements with operational structures, Transfer Pricing documentation, and regulatory expectations.

Our approach focuses on ensuring that agreements accurately reflect commercial conduct, pricing arrangements, operational responsibilities, economic substance, and governance expectations.

We support a wide range of intercompany arrangements including service agreements, financing arrangements, intellectual property structures, cost-sharing arrangements, and management support services.