Transfer Pricing Master File & Local File for Petroleum Companies in the UAE
Get fully compliant, FTA-ready transfer pricing documentation tailored for oil & gas businesses. Prepared by UAE transfer pricing expert Ezat Alnajm and the team at Tulpar Global Taxation.
Transfer Pricing Master File & Local File Services in the UAE for Petroleum Companies
Petroleum and energy companies in the UAE face some of the strictest transfer pricing expectations due to high-value cross-border transactions, intercompany services, and commodity-based pricing. With the introduction of UAE Corporate Tax, preparing a compliant Transfer Pricing Master File and Local File is now mandatory for qualifying entities especially oil & gas groups with global operations.
Tulpar Global Taxation provides expert transfer pricing documentation tailored specifically for petroleum companies. Led by Ezat Alnajm, one of the UAE’s leading transfer pricing specialists, our team ensures your Master File and Local File fully meet OECD and Federal Tax Authority (FTA) requirements.
Why Transfer Pricing Compliance Matters for Petroleum Companies
Oil & gas companies have complex structures, making them high-risk targets for FTA audits. Proper documentation helps you:
- Avoid penalties and compliance risks
- Justify intercompany pricing during FTA reviews
- Strengthen audit readiness
- Maintain alignment with global tax standards
- Demonstrate transparency in high-value related-party transactions
For petroleum groups, transfer pricing compliance is not optional, it’s essential.
Master File Services for UAE Petroleum Groups
The Master File provides a group-wide overview and is mandatory for businesses with large global operations or cross-border related-party transactions.
Your Master File will include:
- Global organizational and ownership structure
- Description of the petroleum group’s worldwide value chain
- Overview of exploration, production, processing, and supply-chain activities
- Details of intercompany financing, procurement, R&D, and marketing
- Consolidated financials and global tax positions
- Benchmarking aligned with global commodity pricing
Our Master File ensures your petroleum operations are transparent, defensible, and fully compliant.
Meet Our Experts
Our Dedicated Team of Accountants is Here
Ezat Alnajm
FTA Tax Agent
Sivanandan Shibu
FTA Tax Agent
Modar Alnajm
Director of marketing
Gamal al gafni
Senior Business Consultant
Local File Preparation for UAE Petroleum Entities
The Local File is UAE-specific and explains the arm’s-length nature of every related-party transaction.
For petroleum companies, this typically covers:
- Crude oil & refined product trading
- Intercompany drilling, geological, and technical services
- Storage, logistics, and pipeline operations
- Shared services and management fees
- Licensing of technology or proprietary extraction methods
- Intercompany financing or treasury functions
- Support functions in regional petroleum hubs
Our analysis includes functional profiles, pricing methodologies, and industry-specific benchmarking aligned with UAE law and OECD guidelines.
Unique Challenges for Petroleum Companies
We help you manage complexities such as:
- Transfer pricing during fluctuating oil prices
- Cross-border oilfield services
- Commodity trading hubs in the UAE
- High-value capital-intensive projects
- Cost-sharing for exploration & technical services
- Intercompany loans for upstream/downstream financing
These factors often trigger FTA scrutiny, Tulpar ensures your documentation is audit-ready.
Why Choose Tulpar Global Taxation
- Specialized experience with UAE petroleum and energy sector
- Transfer pricing models tailored to commodity and extraction businesses
- Fully compliant with Article 55 of UAE Corporate Tax
- Clear documentation that withstands FTA scrutiny
- Fast delivery and full support before, during, and after audits
Meet Ezat Alnajm — UAE Transfer Pricing Expert
Our practice is led by Ezat Alnajm, one of the UAE’s most trusted transfer pricing advisors. With years of experience supporting multinational petroleum groups, he delivers:
- Precise, audit-proof transfer pricing documentation
- Deep understanding of OECD and UAE regulations
- Customized solutions for oil & gas operations
- Strategic tax planning across multiple jurisdictions
His expertise ensures your petroleum company is fully protected and compliant.
Compliance Checklist for Petroleum Companies
Petroleum companies in the UAE must prepare:
- ✓ Transfer Pricing Master File
- ✓ Transfer Pricing Local File
- ✓ Disclosure Form with annual tax return
- ✓ Arm’s-length justification for all related-party transactions
- ✓ Benchmarking studies for commodity and service transactions
Tulpar Global Taxation handles all of these for you.
FAQs:
Yes. We specialize in providing transfer pricing services to Oil & Gas and Petroleum companies, including upstream, midstream, and downstream operations. Our team understands sector-specific pricing models, cross-border transactions, and regulatory requirements unique to the industry.
We provide end-to-end transfer pricing support, including Master File, Local File, CBCR, TP Study Reports, benchmarking analysis, intercompany pricing models, and all required documentation for compliance with Indian and global tax authorities.
The Master File is a high-level document required under BEPS Action 13 that provides an overview of your global business, intangibles, intercompany financing, and allocation of income. Petroleum companies with international operations or group entities must prepare a Master File to stay compliant.
Yes. We manage end-to-end CBCR preparation, filing, notifications, and compliance for multinational petroleum companies. Our CBCR services ensure accurate reporting of global revenue, profits, taxes, employees, and operations across jurisdictions.
Absolutely. We prepare comprehensive Transfer Pricing Study Reports tailored to oil & gas transactions such as crude imports, equipment leasing, drilling services, cost sharing, and other intra-group activities. Our reports meet statutory requirements and reduce audit risks.
We use global databases and petroleum-specific comparable to benchmark drilling services, engineering services, procurement operations, R&D, management fees, royalty payments, logistics, and more. This ensures accurate ALP and audit-proof documentation.
Yes. We design, implement, and review intercompany pricing models for upstream, midstream, and downstream operations. This includes pricing for crude procurement, technical services, pipeline usage, capital equipment, and management services.
Yes. Petroleum businesses with cross-border related-party transactions must prepare both documents under UAE Corporate Tax and OECD BEPS.
Qualified tax and transfer pricing professionals like Tulpar Global Taxation, led by Ezat Alnajm, are authorized to prepare compliant TP documentation.
The OECD master file gives a global overview, while the local file details country-specific transactions. Compliance with transfer pricing master file and transfer pricing local file requirements ensures proper documentation.
Tulpar Global Taxation stands as a premier company in the United Arab Emirates, specializing in taxation, accounting, and auditing services.
Our Branches
HEAD OFFICE
Aspect Tower - Office No.2206 - Zone B Bay Avenue - Business Bay - Dubai
AJMAN FREE ZONE BRANCH
Executive Office - 317, Building A1 Ajman Free Zone
SHARJAH SAIF ZONE BRANCH
Saif Zone Y-32 Sharjah U.A.E
