Who owns whom, every related-party transaction, the method behind each price and the evidence that supports it — connected directly to the Corporate Tax return.
Trading LLC · related-party transactions · FY 2026
Amounts in AED · benchmark ranges are interquartile · figures are illustrative
| Invoice | Related party | Description | Cost | Price | Margin | ALP range | Method | ALP check | Suggested | Adjustment |
|---|---|---|---|---|---|---|---|---|---|---|
| INV-26-041214 Jan 2026 | Parts LLCGoods | Brake assemblies × 1,200 | 486,000 | 558,900 | 15.0%mark-up | 12.0 – 18.5% | CUP | Arm's length | 15.0% | — |
| INV-26-043831 Mar 2026 | Holding LLCServices | Shared finance & HR services, Q1 | 320,000 | 336,000 | 5.0%mark-up | 5.0 – 8.0% | CPM | Arm's length | 5.0% | — |
| INV-26-047122 Apr 2026 | OpCo BGoods | Lubricants for distribution | 1,150,000 | 1,173,000 | 2.0%net mark-up | 6.5 – 11.0% | TNMM | Below range | 8.4% | +73,600 |
| INV-26-050330 Jun 2026 | OpCo AServices | IT support & licences, H1 | 240,000 | 300,000 | 25.0%mark-up | 7.0 – 12.0% | CPM | Above range | 9.5% | −37,200 |
| LN-26-00071 Jul 2026 | Holding LLCFinancing | Loan of AED 5,000,000 for 12 months | — | 150,000 | 3.0%interest p.a. | 5.4 – 6.4% | CUP | Below range | 5.9% | +145,000 |
| INV-26-055918 Aug 2026 | OpCo BGoods | Spare parts for resale | 860,000 | 1,000,000 | 14.0%gross margin | 12.0 – 20.0% | RPM | Arm's length | 14.0% | — |
| Net adjustment to arm's length, carried to the Corporate Tax return | +181,400 | |||||||||
Parts LLC Goods
Brake assemblies × 1,200
INV-26-0412 · 14 Jan 2026
Holding LLC Services
Shared finance & HR services, Q1
INV-26-0438 · 31 Mar 2026
OpCo B Goods
Lubricants for distribution
INV-26-0471 · 22 Apr 2026
Adjustment AED +73,600
OpCo A Services
IT support & licences, H1
INV-26-0503 · 30 Jun 2026
Adjustment AED −37,200
Holding LLC Financing
Loan of AED 5,000,000 for 12 months
LN-26-0007 · 1 Jul 2026
Adjustment AED +145,000
OpCo B Goods
Spare parts for resale
INV-26-0559 · 18 Aug 2026
Related parties, connected persons and every related-party transaction tested at arm’s length — with suggested margins, all five OECD methods and adjustments carried to Corporate Tax.
Record who owns whom, and from when. TRICS draws the organogram for any date and derives related parties and connected persons from it.
Each related-party invoice, service charge and loan is recorded with its item, cost, price, margin and counterparty.
Every transaction is tested against its benchmark range. Where it falls outside, TRICS suggests an arm’s length margin and the adjustment it implies — the preparer decides.
ALP studies, benchmarking sets and intercompany agreements are kept with the transactions they support.
Keep track of the thresholds for the transfer pricing disclosure form, master file and local file across your entities.
Transfer pricing adjustments flow to the Corporate Tax return of the entity concerned, split across the related-party rows they relate to.
The preparer chooses the method for each transaction; TRICS applies it consistently and checks the result against the benchmark.
Comparable Uncontrolled Price
The same goods, services or loans priced between independent parties.
Resale Price Method
Distributors that resell without adding much value.
Cost Plus Method
Services and contract manufacturing, priced on cost.
Transactional Net Margin
The net margin of the simpler party when no direct comparable exists.
Profit Split Method
Highly integrated operations where both sides add unique value.
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