Dubai desk · Transfer Pricing
If an Indian company and a UAE company are associated enterprises, the price of goods, services, royalties, and finance between them is a tax file in both countries. UAE corporate tax now expects arm’s-length related-party dealings. India still expects Form 3CEB and TP documentation. PJRJ keeps those two files on the same facts.
What we work on
Impact and scoping
Map the India–UAE value chain: who does what, where the people sit, and which related-party flows exist — goods, management fees, IP, guarantees, or loans.
Documentation
Coordinate local-file / master-file style papers where UAE thresholds apply, the FTA related-party disclosure, and the Indian TP report plus Form 3CEB.
Pricing of intra-group charges
Support arm’s-length positions on management fees, royalties, shared services, and intercompany finance — not a brochure markup.
PE and attribution
If Indian personnel or a dependent agent creates a permanent establishment risk, profit attribution has to match the DTAA analysis on the India–UAE tax page.
Flows we see on India–UAE groups
- Goods sold from India to a Dubai trading company, or the reverse
- Management, IT, or back-office charges from India into the UAE entity
- Royalty or brand fees
- Shareholder loans, guarantees, and cash pooling
- Cost-sharing for founders splitting time between Delhi and Dubai
- Customs value on imports that should not contradict the TP price
UAE side — what to expect
- Related-party transactions generally need to meet the arm’s-length standard under UAE corporate tax
- Disclosure with the corporate-tax return where the FTA requires it
- Master file and local file when the group meets published size or materiality thresholds
- Country-by-country reporting for groups already in a CbC regime
- VAT and customs: a TP adjustment can have invoice, VAT, and customs consequences — we flag that before you book it
India side — what to expect
- Associated-enterprise tests under the Income-tax Act
- Accountant’s report in Form 3CEB where the value of international transactions crosses the threshold
- Contemporaneous documentation and, where useful, a benchmarking study
- Withholding and Form 15CA/CB on the same payment the TP file prices
How a TP engagement runs
- 1List every related-party contract and the people who actually perform the work.
- 2Characterise each flow and pick a pricing method that matches the facts.
- 3Align UAE books, FTA disclosure, and the Indian 3CEB pack to the same numbers.
- 4Review VAT, customs, and PE risk before year-end journals.
- 5Refresh the file when the licence, headcount, or financing changes.
PJRJ’s international tax desk in Delhi and Gurgaon leads the analysis. UAE FTA filings that must be signed locally are executed with UAE tax partners. OECD-style methods inform the work; the legal tests are UAE corporate tax and the Indian TP provisions. This page is general information, not an audit opinion or a safe-harbour certificate.
India–UAE Transfer Pricing FAQs
Size thresholds differ in India and the UAE. Even below a documentation threshold, related-party prices can be questioned. We scope whether a full local file, a lighter memo, or only disclosure is proportionate.
Yes, if people in India actually provide the service, the fee is arm’s length, invoices exist, and withholding / 15CA/CB are handled. A fee with no substance is a common FTA and Indian TP adjustment.
No. They share OECD language but are separate statutes, forms, and due dates. We prepare one fact pattern that can support both files.
Discuss your Transfer Pricing requirements
Speak with a PJRJ Dubai desk partner — we respond within one business day.