TP Country Profile
United Arab Emirates Transfer Pricing Country Profile
Legal framework, pricing methods, documentation, reporting and dispute routes, with a legal cut-off of 16 October 2026.
Edition 1.0
Legal cut-off: 16 October 2026
Corporate Tax periods beginning on or after 1 June 2023 (focus on 2025 and 2026); CbCR fiscal years beginning from 1 January 2019
United Arab Emirates transfer pricing in brief
The United Arab Emirates applies an arm's length rule to related-party dealings, and a market-value rule to payments to connected persons, under its federal Corporate Tax Law (Federal Decree-Law No. 47 of 2022) for tax periods beginning on or after 1 June 2023. Article 34 has no minimum transaction value, so the documentation thresholds decide what has to be prepared, not whether the arm's length standard applies. The gate that matters most is the Local File and Master File duty, which applies at AED 200 million of the entity's own revenue or AED 3.15 billion of group revenue.
United Arab Emirates transfer pricing at a glance
Topic | Headline position |
|---|---|
Law | Federal Decree-Law No. 47 of 2022 (Corporate Tax Law): Article 34 (arm's length), Articles 35 and 36 (related parties and connected persons) and Article 55 (disclosures and documentation), for tax periods beginning on or after 1 June 2023 |
Standard | Arm's length for domestic and cross-border dealings with related parties, with no minimum transaction value; payments to connected persons must also be at market value |
Methods | Comparable Uncontrolled Price, Resale Price, Cost Plus, Transactional Net Margin and Transactional Profit Split; another method only if none of these can reasonably be applied |
Documentation | Local File and Master File, produced to the Federal Tax Authority on request rather than filed with the return; reliable evidence is still needed below the thresholds |
Master File | Required together with the Local File if the entity's own revenue is AED 200 million or more, or its multinational group's consolidated revenue is AED 3.15 billion or more |
Group reports | Country-by-country report filed with the Ministry of Finance by a UAE-resident ultimate parent of a group with consolidated revenue of AED 3.15 billion or more in the preceding year, using the OECD template |
Other reporting | Related Party Schedule and Connected Person Schedule in the Corporate Tax return, each with its own value threshold; a downward transfer pricing adjustment triggers disclosure of all affected related-party transactions |
Disputes | Unilateral Advance Pricing Agreements for qualifying domestic arrangements, Mutual Agreement Procedure through the Ministry of Finance, and domestic assessment review, reconsideration and appeal routes |
What the full profile covers
The full 20-page profile includes:
Legal framework, covered persons and connected persons, and special regimes
Methods, benchmarking and comparability
Local File, Master File, country-by-country reporting and Corporate Tax return disclosures
Transaction-specific rules, permanent establishment profit attribution and simplified treatment
Adjustments and implementation, including year-end true-ups
Audits, penalties and limitation periods
Advance Pricing Agreements, Mutual Agreement Procedure and appeals
Recent developments and practical priorities
Download the full profile for the return schedule thresholds, penalty tables, the simplified treatment for low value-adding services and the dispute timelines.
Frequently asked questions
What is transfer pricing in the United Arab Emirates?
Under the Corporate Tax Law (Federal Decree-Law No. 47 of 2022), dealings with related parties must meet the arm's length standard for tax periods beginning on or after 1 June 2023. Article 34 covers domestic and cross-border arrangements with no minimum transaction value, and Article 36 applies a market-value test to payments to connected persons. The Federal Tax Authority administers the rules.
Does the United Arab Emirates require a Local File or Master File?
Yes, in two cases. A taxable person must maintain both files if its own revenue for the tax period is AED 200 million or more, or if it belongs to a multinational group with consolidated revenue of AED 3.15 billion or more. The files are produced to the Federal Tax Authority on request and are not filed with the annual return. Entities below the thresholds still need reliable contracts, financial evidence and pricing support.
Who must file country-by-country reporting?
A UAE-resident ultimate parent of a multinational group with consolidated revenue of AED 3.15 billion or more in the preceding fiscal year, where the group has entities resident in at least two jurisdictions. The report follows the OECD template and goes to the Ministry of Finance. The rules reviewed do not require every UAE subsidiary of a foreign-parented group to file locally.
What other returns apply to foreign-owned entities?
Related-party dealings and payments to connected persons are disclosed in schedules to the Corporate Tax return, each triggered by its own value threshold, and these are separate from the Local File and Master File. If a taxpayer makes a downward transfer pricing adjustment under Article 34(1), all affected related-party transactions must be disclosed whatever their value (FTA Public Clarification CTP011, July 2026).
What are the transfer pricing dispute options?
The Federal Tax Authority has run a unilateral Advance Pricing Agreement process for qualifying domestic arrangements since December 2025; cross-border and bilateral programmes are described as later phases. The Ministry of Finance handles Mutual Agreement Procedure requests under double tax treaties. Domestic routes are a tax assessment review, reconsideration, and then the Tax Disputes Resolution Committee and the courts.
Where can I get the full United Arab Emirates transfer pricing profile?
Download the 20-page United Arab Emirates Transfer Pricing Country Profile (Edition 1.0, legal cut-off 16 October 2026).
Related services
Prepared by AventaaGlobal Advisors LLP. Edition 1.0, legal cut-off 16 October 2026. This summary is for general information and is not legal or tax advice.