Cross-Border & Specialized Tax — Transfer Pricing
Transfer pricing documentation is now a compliance requirement, not a formality — the UAE's Corporate Tax law and Saudi Arabia's Zakat, Tax and Customs Authority both expect related-party transactions to be priced and documented at arm's length. FMCA's advisory practice prepares the Master File, Local File and disclosure forms cross-border groups need, coordinated across both jurisdictions from one team.
Reviewed by FMCA's Senior Tax Advisory Team — registered FTA tax agents serving clients across the UAE and Saudi Arabia.
Four areas of documentation and structuring work, built for groups operating related entities across the UAE and Saudi Arabia.
Disclosure forms and supporting documentation prepared to meet UAE Corporate Tax and KSA ZATCA requirements as they actually apply to your structure.
Every intercompany transaction — pricing, financing, service charges — reviewed against the arm's-length standard before it's questioned.
The two-tier documentation multinational groups need — group-wide structure in the Master File, entity-specific detail in the Local File.
Intercompany arrangements structured to hold up under both tax authorities at once, not just the one that audits first.
Related-party transactions without a defensible pricing rationale are one of the first things a tax authority tests.
Undocumented intercompany transactions are a standard first point of inquiry — precisely because they're the easiest place to shift profit.
Missing or inadequate documentation can trigger penalties independent of whether the underlying pricing was actually correct.
A pricing adjustment made by one authority without matching relief in the other jurisdiction can tax the same profit twice.
This page covers the documentation and structuring service itself — for the underlying rules, see our related read: Transfer Pricing in the UAE: The Tax Rule, and for the corporate tax filing it feeds into, see Corporate Tax Services.
Both sit under the same OECD-aligned framework, but they answer different questions for different audiences.
Our Approach
Transfer pricing sits at the intersection of two tax regimes, and most advisors only know one side of it. FMCA's tax advisory team — the same registered agents who file UAE Corporate Tax and KSA Corporate Tax & Zakat — prepares documentation that holds up under both authorities, not just the one that happens to ask first.
How We Work
Illustrative scenarios based on the kind of work we do — not descriptions of specific named clients.
Related-party goods pricing documented with a defensible arm's-length rationale before either tax authority raised a question, not after.
Group-wide structure documented the quarter the consolidated revenue threshold was crossed, avoiding a retroactive scramble.
A management fee arrangement reworked so the same rationale satisfies both UAE Corporate Tax and KSA ZATCA review, not two conflicting positions.
Related Insights
FAQ
The arm's-length requirement applies to any related-party transaction, regardless of size. The Master File and Local File thresholds are what scale with group revenue — not the underlying pricing obligation itself.
Sales of goods, services, financing, management fees, royalties and cost-sharing arrangements between entities under common ownership or control — in either direction.
No — our article on the underlying rule stays as background reading. This page covers the documentation and advisory service itself.
Transfer pricing disclosure forms and supporting documentation are prepared alongside the Corporate Tax return, not as a separate, disconnected filing.
The underlying transaction analysis can largely be shared, but the disclosure forms and filing format differ between the FTA and ZATCA — FMCA prepares both from one file.
Tell us where things stand and a senior consultant will get back to you directly — not a call centre.
