UAE Corporate Tax brought transfer pricing into everyday compliance. Transactions between related parties must now be priced at arm’s length (Article 34), and payments to connected persons — owners, directors and their relatives — are deductible only up to their market value (Article 36). The Board needs to know what documentation those rules create.
The arm’s-length principle, applied
Related-party transactions — management fees, intra-group loans, shared services, IP charges — must be priced as they would be between independent parties, supported by a recognised transfer-pricing method. Mispricing is not just an adjustment risk; it can shift taxable income between entities and draw FTA scrutiny.
What documentation is expected
Depending on group size and revenue, obligations escalate from a transfer-pricing disclosure form filed with the return, up to a full master file and local file for larger groups, with thresholds set by the FTA. A Board should expect, at minimum: a related-party transaction register, a documented pricing policy, and benchmarking support proportionate to the group’s size — confirm the exact thresholds that apply to you.
General guidance on UAE Corporate Tax transfer pricing; confirm current thresholds and filing requirements against the latest FTA guidance.