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Transfer pricing work is only as good as the transaction data behind it. Set up the ERP so every related party and connected person deal is tagged when it is posted, not hunted down at year-end.
For UAE transfer pricing, an ERP should tag related parties and connected persons on customer, supplier and employee records, categorise their transactions to match disclosure schedules, reconcile intercompany postings and produce year-end extracts for advisors. Under the Corporate Tax Law, Federal Decree-Law No. 47 of 2022, such transactions must meet the arm's length standard. Advisors still choose methods and benchmarking.
A UAE transfer pricing ERP setup is not a pricing engine. Your advisors still choose the method, run the benchmarking and write the documentation. What the ERP controls is whether the facts they need are complete: who the related parties are, which transactions happened with them, how much was charged, and how those amounts appear in the financial statements.
Under Federal Decree-Law No. 47 of 2022, the Corporate Tax Law, transactions with Related Parties and Connected Persons must meet the arm's length standard (Article 34). Related Parties are defined in Article 35 and Connected Persons, such as owners, directors and officers and their related parties, in Article 36. The FTA's Transfer Pricing Guide explains how these definitions work in practice.
Most UAE groups we meet already post intercompany charges, shareholder loans and management fees. The gap is classification. Without a counterparty tag and a transaction category, someone exports a year of ledger lines and filters them by hand, usually under deadline. If you are still building the wider tax setup, start with our UAE corporate tax ERP page.
These points come from the Corporate Tax Law, Ministerial Decision No. 97 of 2023 and FTA guidance. This page is general information and not tax advice: thresholds and forms can change, so confirm your position with your tax advisor.
Transactions with Related Parties and Connected Persons should be priced as if they were between independent parties in similar circumstances. The FTA can adjust taxable income where they are not, and downward adjustments in your favour require an application to the FTA.
Ministerial Decision No. 97 of 2023 requires a master file and local file where the taxable person's revenue in the tax period is 200 million dirhams or more, or where it belongs to a multinational group with consolidated revenue of 3.15 billion dirhams or more. These files are produced within 30 days of an FTA request rather than filed routinely.
The FTA's Tax Returns guide says the related party disclosure applies where related party transactions exceed 40 million dirhams in total, and then only categories above 4 million dirhams are disclosed. Dividends paid to related parties are left out of those calculations.
Payments or benefits to a Connected Person (with its related parties) are disclosed where they exceed 500,000 dirhams. Salaries, bonuses, rent or fees paid to owners and directors are the usual examples, so payroll and AP data both matter.
The disclosure is made with the corporate tax return, which is due within nine months of the end of the tax period. Supporting records follow the corporate tax retention period of seven years.
General information, not tax or legal advice. Rules change; confirm current FTA, MOHRE and Ministry of Finance guidance with your advisor.
Run these checks before your first full corporate tax year closes. Each item removes a manual step from the year-end disclosure.
The agreement sets the price; the ERP records what actually happened. Your advisors compare the two and document the result.
One shared database: every step updates stock, finance and reports in real time.
All four platforms can hold the tags and categories described above. The differences are in multi-entity handling and reporting depth. Confirm details against your edition and version.
| Zoho Books | Odoo | ERPNext | Dynamics 365 Business Central | |
|---|---|---|---|---|
| Related party tagging | Custom fields on contacts | Contact tags or custom fields | Custom fields and customer or supplier groups | Dimensions or custom fields on vendors and customers |
| Multi-entity intercompany | Separate organizations with manual or automated mirroring | Multi-company with inter-company rules for documents | Multi-company with inter-company invoices | Intercompany postings across companies in one tenant |
| Category reporting | Reports by account and custom field, or Zoho Analytics | Analytic accounts and pivot reports | Accounting dimensions and query reports | Dimensions with account schedules |
| Consolidation | Usually via Zoho Analytics or external tools | Consolidation options vary by version | Consolidated financial statement reports | Built-in consolidation features |
| Best fit | Smaller groups with few intercompany flows | Groups running trading and services entities on one database | Groups wanting open-source control | Larger groups with many entities and currencies |
No ERP determines an arm's length price. Pricing method, benchmarking and documentation remain the work of your tax advisors.
These ranges assume an existing ERP that needs tagging and reporting added. A new multi-entity implementation follows the same steps inside a longer project.
Durations are typical ranges; your plan is agreed after discovery.
With your advisor, we confirm the list of related parties and connected persons and agree the transaction categories.
We add flags, dimensions and accounts for intercompany flows, and design the monthly matching process between entities.
Open tax periods are reviewed and existing transactions are tagged so the first disclosure covers the whole year.
We build the year-end extract and train finance to run it, then walk your advisor through the output.
Transfer pricing data sits on top of your corporate tax and multi-entity setup.
On-site workshops in Dubai, Abu Dhabi and Sharjah, and remote or on-site delivery across the Northern Emirates and free zones.
Official sources and references
Facts on this page were checked against these sources in October 2026. Rules change, so confirm current requirements before acting.
Still have a question? Our consultants are happy to help.
Ask an ExpertYes, in the sense that the arm's length principle applies whatever your size. Master file and local file obligations and the disclosure schedules have thresholds, but you still need to know who your related parties and connected persons are and what you paid them. Your advisor can confirm which obligations apply.
It can be. Owners and directors are usually Connected Persons, and payments to them are expected to be at market value and for the benefit of the business. Tag them in payroll and AP so the totals are visible, and discuss the amounts with your tax advisor.
Not on its own. The ERP supplies the financial data, transaction lists and segment figures. The files themselves include functional analysis, pricing methods and benchmarking that your advisors prepare.
Transactions between a Qualifying Free Zone Person and mainland group companies attract close attention, because they can affect qualifying income. Keep the entities in separate companies within the ERP and tag every intercompany flow. Confirm the free zone position with your tax advisor.
Corporate tax records are kept for seven years after the end of the tax period they relate to. Keep agreements, invoices and calculations together so the FTA can follow each transaction if it asks.
Dynamics 365 Business Central and Odoo both handle multi-company work well, and ERPNext suits groups wanting open-source control. Zoho Books works for smaller groups with simple flows. The right choice depends on entity count, currencies and consolidation needs.
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Send us your group structure and intercompany accounts, and we will show how to tag them for the next corporate tax return.
Dubai, United Arab Emirates
