In today’s interconnected global economy, Transfer Pricing (TP) plays a critical role in how Multinational Enterprises (MNEs) manage taxation across jurisdictions. With tax authorities worldwide intensifying their focus on Base Erosion and Profit Shifting (BEPS), and demanding greater transparency through initiatives like Country-by-Country Reporting (CbCR) and Automatic Exchange of Information (AEOI), transfer pricing has become a top compliance priority.

Transfer Pricing refers to the valuation of transactions—such as goods, services, financing, and intellectual property—between related entities of an MNE operating in different countries. These cross-border intra-group transactions must meet arm’s length standards and be properly documented to satisfy both local regulations and OECD guidelines.

Failure to manage TP exposure effectively can lead to audits, adjustments, double taxation, and reputational risk. That’s why MNEs need a clear, defendable, and operationally sustainable transfer pricing framework aligned with commercial realities and value creation.

How Goldstone Supports You with Transfer Pricing

At Goldstone, our experienced Transfer Pricing advisors and international tax consultants help you navigate regulatory demands while optimizing your global tax position. We take a practical, business-aligned approach to transfer pricing risk management and planning.

Our Transfer Pricing Services Include:

• TP Strategy & Model Development
  Structuring tax-efficient, globally defensible TP models aligned with OECD and UN TP guidelines, as well as local legislation.

• TP Documentation & Compliance
  Preparing local files, master files, and benchmarking studies that meet UAE TP law and BEPS documentation requirements.

• TP Risk Reviews & Due Diligence
  Conducting transfer pricing health checks to identify gaps, mitigate audit risks, and refine your policy framework.

• Business Restructuring & Value Chain Planning
  Advising on TP implications of global business transformations, supply chain realignments, and intercompany transactions.

• Contract Review & Policy Drafting
  Drafting, reviewing, and vetting intercompany agreements to ensure legal compliance and defendability in audits.

• TP Compliance Filings & Disclosure Support
  Supporting clients with preparation and submission of TP certificates, forms, and required disclosures in tax returns.

• Insights on BEPS Action Plans 8–10
  Providing technical guidance on aligning TP outcomes with economic substance and value creation, especially for IP and intangibles.

• Customs Valuation Interplay
  Advising on how TP policies interface with customs obligations, reducing the risk of duty and tax disputes.