UAE Corporate Tax brought full OECD-aligned transfer pricing (TP) rules for the first time. Every transaction between related or connected persons must be priced at arm's length — and larger groups must maintain formal documentation. Here's what applies to whom.
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Documentation thresholds
- Master File and Local File required if group revenue ≥ AED 3.15 billion OR UAE entity revenue ≥ AED 200 million
- Transfer pricing disclosure form: required in the CT return for material related-party transactions
- Documentation must be ready by the CT return due date (9 months after year-end)
Common arm's-length methods
- Comparable Uncontrolled Price (CUP)
- Resale Price Method
- Cost Plus
- Transactional Net Margin Method (TNMM) — most commonly used for services
- Profit Split
Practical SME checklist
- Identify every related and connected party (owners, siblings, group companies)
- Document intercompany service fees, royalties, loans and management charges
- Benchmark director/owner salaries against market rates
- Retain contracts and evidence for the FTA's 7-year window
Even below documentation thresholds, every UAE taxpayer must apply arm's-length pricing and be able to justify it if the FTA asks.
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Frequently asked questions
Quick answers to common UAE corporate tax questions.
This article is for general guidance only and reflects FTA rules as of June 2026. Always confirm your specific position with a qualified UAE tax advisor.