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Transfer Pricing: The Nexus Trap

Related Party Compliance and Arm's Length Principle Enforcement in 2025/26

Feb 17, 2026
10 min read
Arakan Statutory Team

The Audit Focus

The FTA has signaled that Transfer Pricing (TP) will be the primary lever for revenue protection in the upcoming audit cycles. Any transaction between 'Connected Persons' must adhere to the Arm's Length Principle.

Primary Penalty

AED 50,000

Per instance of missing Master File documentation.

Forensic Nexus Mapping

Most conglomerates fail because their ERP systems lack the 'Nexus Layer' required to tag related-party transfers automatically. Arakan solves this by building a secondary forensic ledger in volatile memory.