Navigate the UAE Corporate Tax landscape with confidence. Ensure compliance with Federal Tax Authority (FTA) standards and OECD-aligned Transfer Pricing requirements.
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With the implementation of Corporate Tax in the UAE, Transfer Pricing has become a statutory requirement. Under Federal Decree-Law No. 47 of 2022, all transactions between related parties and connected persons must comply with the Arm’s Length Principle.
The UAE framework closely follows OECD guidelines, requiring businesses to maintain documentation that justifies their pricing policies and intercompany arrangements to the Federal Tax Authority.
The legal foundation in the UAE CT Law mandating the Arm’s Length Principle for Related Parties and Connected Persons.
Specifies the thresholds and standards for maintaining Master Files and Local Files within the UAE jurisdiction.
Provides clarity on the requirements for maintaining Transfer Pricing documentation and the submission of Disclosure Forms.
Strategic overview of the MNE group's global business and TP policies.
Required if the taxable person is part of an MNE Group with a consolidated group revenue of at least AED 3.15 billion, or if the taxable person’s revenue in the relevant tax period is at least AED 200 million.
The Master File must contain information on the group's organizational structure, business descriptions, intangibles, and intercompany financial activities.
Detailed transactional analysis for the UAE entity.
Thresholds for the Local File match the Master File (AED 200m revenue or part of a large MNE group). It focuses on the specific transactions between the UAE entity and its foreign related parties.
Documentation must include a functional analysis (Functions, Assets, and Risks), selection of the most appropriate TP method, and benchmarking analysis.
Mandatory reporting of related party transactions.
All taxable persons engaged in transactions with Related Parties and Connected Persons may be required to file a Disclosure Form along with their Tax Return.
The form captures the nature and value of transactions, the TP methods used, and confirmation that the Arm's Length Principle has been applied.
Aligning your TP policy with UAE Corporate Tax laws.
Preparation of FTA-compliant documentation sets.
Local and regional database searches for arm's length ranges.
Management of connected person payments and risk mitigation.
Ensure your transfer pricing documentation is robust and compliant before the filing deadline.
Contact ExpertsFor further information on transfer pricing please contact:
Leader - Gulf Practice
Leader - Global TP
Leader - TP Policy
TP Specialist – Gulf Region