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Our Expertise: From Compliance to Strategy
  • Strategic Advisory & Policy Design
    We help you build a sustainable TP framework from the ground up:
    • Analysis of intra-group transactions and identification of transfer pricing risks.
    • Assessment of risks arising in the UAE from existing group transfer pricing policies.
    • Selection of appropriate transfer pricing methods to support arm’s length pricing and profit allocation among group companies.
    • Development and implementation of sustainable transfer pricing policies for operations in the UAE and other jurisdictions, including methodology selection, detailed policy design, and periodic adjustment mechanisms.
    • Methodological and administrative support in applying for Advance Pricing Agreements (APA)
  • Economic Analysis & Benchmarking
    We provide robust data-driven support:
    • In-depth economic analysis based on publicly available information and internal corporate data to determine arm’s length prices or margins for controlled transactions.
    • Analysis of arm’s length remuneration for beneficiaries.
  • Documentation & Compliance
    We ensure your documentation meets the highest standards of the FTA:
    • Preparation of transfer pricing documentation, including industry, company, functional, economic, and financial analyses, as well as three-tier documentation (Local File, Master File, and Country-by-Country Report). Where required, we assist in adapting country data and identifying risks within the global group structure through CbCR assessments.
    • Review of taxpayers’ economic substance in the UAE and provision of recommendations for its enhancement or restructuring to meet local regulatory requirements.
  • Operating Model & Value Chain Transformation
    We help you structure your business for efficiency and tax certainty:
    • Design and implementation of limited-risk structures involving procurement and sourcing functions, R&D activities, manufacturing, and distribution.
    • Support in adapting operating models by developing alternative scenarios that address UAE regulatory requirements and the integration of new entities into the supply chain, including defining target profit allocation mechanisms and cost center structures.
    • Methodological support in relation to intangible property (IP), including identification and confirmation of economic and legal ownership (DEMPE analysis), analysis of IP transfer options, and assessment of related tax, customs, and transfer pricing implications.
    • Implementation of profit allocation between a permanent establishment and its head company.
  • Dispute Resolution & Certainty
    We stand by you in interactions with tax authorities:
    • Management and support of transfer pricing audits, disputes, and controversy proceedings.
SELECTED CLIENT EXPERIENCE
  • Mining & Metals
    Preparation of a full set of transfer pricing documentation (TP Disclosure Form, Master File, CbCR notification, and Local File) for a large multinational mining corporation with its Ultimate Parent Entity in the UAE.

    Let’s discuss your case →
  • Trading & Commodities (DMCC)
    Development of transfer pricing policy for a UAE-based trading company, specifically addressing the pricing of commodities and intra-group services.

    Let’s discuss your case →
  • Financial Services (ADGM)
    Conducting benchmarking studies for back-to-back loan agreements to determine arm’s length interest rate levels for a financial company.

    Let’s discuss your case →
  • Asset Management (DIFC)
    Preparation of complex TP documentation using a profit split method for an asset management firm.

    Let’s discuss your case →
WHY CHOOSE BAONE
  • Local knowledge and global reach
    In-depth local market knowledge and extensive international experience enable us to offer unique insights and recommendations for your business.
  • Comprehensive support
    BaOne provides integrated consulting and support services at all stages of your company’s entry into the market: from the establishment of an organizational structure to ongoing business support and help with issues of a private nature.
  • Bespoke solutions
    We believe every client is unique, which is why we offer bespoke solutions tailored to your specific business goals and needs.
TAX ALERTS & UPDATES
Corporate Tax Guide on Advance Pricing Agreements
UAE Transfer Pricing Guide. Financial Transactions
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CONTACT US
Learn more about our services by filling in the form below, or email us to request a proposal. Select the appropriate option.
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OUR TEAM

© BaOne FZCO, 2026
Address: Office 304/305, The Offices 2, One Central, Level 3, Dubai, UAE
www.baone.ae
Tel.: +971507417119
info@baone.ae
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