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Taxes in the UAE

Transfer Pricing in the UAE: the Basics

Every transaction between related parties or connected persons must be priced as if between independent parties (the arm’s length principle). Large businesses also keep a master file and local file.

Updated October 2026 · Figures checked 21 October 2026

Revenue from which a business keeps a master file and local file
AED 200m1
Revenue from which a business keeps a master file and local file
Group revenue from which every member keeps them
AED 3.15bn1
Group revenue from which every member keeps them
Related-party transactions above which the disclosure form is filed
AED 40m3
Related-party transactions above which the disclosure form is filed

Transfer Pricing in the UAE: the Basics

Who keeps documentation

  • A business with revenue of AED 200 million or more in the tax period; or
  • A member of a multinational group with consolidated revenue of AED 3.15 billion or more.

Source: UAE Ministry of Finance: Decision on transfer pricing documentation requirements; Federal Tax Authority: Transfer Pricing Guide1,2

The files are kept under Ministerial Decision No. 97 of 2023 and handed to the FTA on request. Qualifying Free Zone Persons must also comply with transfer pricing rules to keep the 0% rate.1,2

Disclosure in the return

A business whose transactions with related parties exceed AED 40 million in total files a transfer pricing disclosure form with its corporate tax return, listing each category of transaction above AED 4 million. Dividends between related parties are left out of both thresholds.3

Sources

  1. UAE Ministry of Finance: Decision on transfer pricing documentation requirements
  2. Federal Tax Authority: Transfer Pricing Guide (PDF)
  3. Federal Tax Authority: Corporate Tax Returns Guide (PDF)

Figures checked 21 October 2026. Prepared by Invest-Emirates.ae for general information. It is not investment, tax or legal advice; please confirm details with a qualified adviser before acting.

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