Transfer Pricing
Transfer pricing that reflects value and withstands scrutiny
Transfer pricing sits at the centre of today’s tax, customs and regulatory scrutiny. As corporate tax regimes expand across the Middle East and global minimum tax rules take effect, pricing that is misaligned with value creation can distort margins, increase exposure and trigger challenge.
We drive measurable competitive advantage by improving agility, reducing costs, and accelerating innovation across the end-to-end value chain - from procurement and manufacturing to logistics and digital integration. Our approach supports businesses in achieving sustainable growth, operational excellence, and long-term value creation.
Combining dedicated regional transfer pricing and controversy teams with deep local insight and global tools, we align policy, operations and documentation - helping turn compliance into a foundation for confident, sustainable growth.
How we can help
Designing transfer pricing models that reflect value creation
We support businesses in developing and implementing transfer pricing strategies that align with their business models. Our services focus on designing defensible transfer pricing frameworks that reflect where value is created, clearly delineate functions, assets and risks, and comply with local and international tax requirements.
By combining technical expertise with commercial insight, we help clients manage risk, support growth initiatives and enhance audit readiness.
Clear, defensible transfer pricing documentation
We help you meet the ever-increasing transfer pricing compliance obligations in our region. By harmonising data, narratives, and TP approach through Master File, Local File, CbCR and other TP compliance preparation, we calibrate local TP regulations and embed consistent methodologies across your business. This helps support you with robust arm’s length outcomes and timely submissions, whilst strengthening your audit readiness.
Driving TP implementation excellence
We develop TP governance frameworks that support the effective implementation of your TP policies, minimising costly errors in compliance, while proactively managing TP risk. By aligning data and technology with process governance, we help you move to having continuous control - reducing surprises and improving real-time visibility over profitability.
Standing firm when pricing is challenged
When tax authorities challenge your transfer pricing, we support you through audits, tax authority negotiations, APAs, MAPs and litigation. We help clients determine their optimal audit defence strategy, whether that be through proactive tax authority engagement using the regions developing APA landscape, or by navigating them through negotiations, litigations and MAPs.
Our dedicated regional controversy team combines local insight with global case experience - focusing on efficient resolution while strengthening your framework to reduce future disputes.
Managing scrutiny on intercompany finance
We advise on transfer pricing for intercompany loans, guarantees, cash pooling and treasury arrangements. From interest rate benchmarking and debt capacity analyses to policy design and compliance, we help align treasury strategy with transfer pricing rules to mitigate risks and enhance opportunities - particularly in volatile-interest-rate and higher-scrutiny environments.
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