The UAE transfer pricing disclosure form is a schedule filed with your corporate tax return. You must complete it if your transactions with related parties exceed AED 40 million in the tax period, or if payments and benefits to a connected person exceed AED 500,000. Once the AED 40 million threshold is passed, each category of transaction above AED 4 million is reported with its value and the transfer pricing method used. Separately, businesses with revenue of AED 200 million or more, or in a group with revenue of AED 3.15 billion or more, must keep a Master File and Local File. This guide explains every threshold and how to fill the form.
Key Takeaways
● The form is part of the corporate tax return. It is due on the same day: 9 months after the end of the tax period.
● AED 40 million is the related-party trigger. Below it, the related-party schedule is not needed.
● AED 500,000 is the connected-person trigger. It catches payments to owners, directors and their relatives.
● Master File and Local File are separate. They apply at AED 200 million revenue or AED 3.15 billion group revenue.
● Everyone must still price at arm's length. The thresholds only decide what you disclose, not whether the rules apply.
Transfer Pricing Rules in the UAE (2026) in Brief
The transfer pricing requirements in the UAE apply to every taxable person, in Dubai and every other emirate: transfer pricing in Dubai follows the same federal rules. Under UAE corporate tax, transactions between related parties and payments to connected persons must be priced at market value: the price independent parties would agree on. This is the arm's length principle in the UAE. If your price is not at arm's length, your taxable income is adjusted. Transfer pricing in the UAE corporate tax return is handled through the disclosure form, which tells the FTA which transactions you had and confirms how you priced them.
Who Needs Transfer Pricing Disclosure in the UAE?
The transfer pricing disclosure form threshold in the UAE has two parts: the transfer pricing disclosure AED 40 million test for related parties and the AED 500,000 test for connected person payments.
Test | Threshold | What you must do |
|---|---|---|
Total related-party transactions in the period | Above AED 40 million | Complete the related-party schedule; list each category above AED 4 million |
Payments or benefits to a connected person (with their related parties) | Above AED 500,000 | Complete the connected-person schedule for each such person |
Taxable person's revenue | AED 200 million or more | Keep a Master File and Local File |
Group consolidated revenue | AED 3.15 billion or more | Keep a Master File and Local File |
Most SMEs fall below every threshold. They do not file the schedules but must still price related-party dealings at arm's length and keep evidence.
Related Party Definition Under UAE Corporate Tax
Under the related party definition in UAE corporate tax, related parties include:
● Individuals related up to the fourth degree, including by marriage
● A person and a company they own or control 50% or more of, directly or indirectly
● Two or more companies controlled 50% or more by the same person or group
● A company and its directors or officers
● A head office and its branch or permanent establishment
● Partners in the same unincorporated partnership
Connected persons are a narrower group: owners, directors and officers of the business, and people related to them.
What the Transfer Pricing Disclosure Form Asks For
Related Party Transactions Disclosure in UAE Corporate Tax
Transactions are grouped into categories: goods, services, intellectual property, interest, assets, liabilities and other. For each category above AED 4 million you report:
● the related party and its country
● the gross amount of income and expense
● the arm's length value
● the transfer pricing method used
Dividends between related parties are not included. Upward adjustments are entered where your price was below market; downward adjustments need FTA approval.
Connected Persons Disclosure in UAE Corporate Tax
For each connected person whose payments and benefits exceed AED 500,000, you report the amount paid and its market value. Any difference is automatically treated as non-deductible in the return. Owner salaries above market rate are the most common example; see our guide to non-deductible expenses in UAE corporate tax.
Transfer Pricing Methods in the UAE
The form asks you to choose one of the five recognised methods, or "Other":
Method | Typically used for |
|---|---|
Comparable Uncontrolled Price (CUP) | Loans, commodities, goods with market prices |
Resale Price Method | Distributors buying from a related supplier |
Cost Plus Method | Related-party services and contract manufacturing |
Transactional Net Margin Method (TNMM) | Most service and distribution arrangements |
Profit Split Method | Highly integrated operations or shared intangibles |
A benchmarking study for UAE transfer pricing, which compares your margins with those of independent companies, is the usual evidence that a price is at arm's length.
Master File and Local File in the UAE
The master file local file threshold is AED 200 million of revenue. The Master File describes the whole group, and the Local File covers the UAE entity's related-party transactions in detail. They are required when the UAE taxable person has revenue of AED 200 million or more, or belongs to a multinational group with consolidated revenue of AED 3.15 billion or more. They are not filed with the return but must be prepared for each period and provided to the FTA when requested. The transfer pricing documentation threshold in the UAE is therefore different from the disclosure form thresholds, and many businesses need one without the other.
How to Fill the Transfer Pricing Disclosure Form on EmaraTax
1. List all related parties and connected persons for the tax period.
2. Total the transactions from your general ledger, including loans and other balance sheet items.
3. Check the thresholds: AED 40 million for related parties, AED 500,000 per connected person.
4. Group transactions by category and identify those above AED 4 million.
5. Confirm the arm's length value and method for each, using benchmarking or internal comparables.
6. Complete the schedules in the corporate tax return on EmaraTax and submit by the return deadline.
The transfer pricing disclosure deadline in the UAE is the same as the corporate tax return: 9 months after the end of the tax period.
Transfer Pricing for SMEs in the UAE
For transfer pricing for SMEs in the UAE, the main risks are owner salaries, family-member payments, loans from shareholders and charges between sister companies. Even below the thresholds, keep a short note explaining how each price was set, such as an employment contract at market salary or a loan at a market interest rate.
Transfer Pricing for Free Zone Companies in the UAE
A Qualifying Free Zone Person must meet the arm's length rules and keep transfer pricing documentation as a condition of the 0% rate. In the return, it confirms that its related-party transactions are at arm's length. Getting this wrong can cost the 0% rate itself. Read more about free zone qualifying income.
Transfer Pricing Penalties in the UAE
There is no single transfer pricing penalty in the UAE, but several apply:
● Taxable income is adjusted to arm's length, with the extra tax due
● Incorrect return penalties and late payment charges on the underpaid tax
● Penalties for not keeping or not providing required records when the FTA asks
Correcting an error through a voluntary disclosure before the FTA raises it keeps penalties lower.
Get Your Transfer Pricing Disclosure Right the First Time
The disclosure form looks simple, but the totals, categories and arm's length values have to match your accounts and stand up to an FTA review. As part of our transfer pricing services in Dubai, our team identifies your related parties and connected persons, checks the thresholds and completes the schedules as part of our corporate tax return filing in Dubai service. For groups, our corporate tax planning and tax group teams review how related-party prices are set. Book a free consultation and we will check whether the form applies to you.