Transfer Pricing in the UAE: Documentation Requirements and Deadlines
UAE Corporate Tax law introduces mandatory Transfer Pricing rules for related-party transactions. Businesses must maintain benchmarking studies and TP documentation — or face significant penalties.
The UAE Corporate Tax Law introduces comprehensive Transfer Pricing (TP) rules under Articles 34–36, requiring all related-party and connected-person transactions to be conducted at arm's length.
Documentation requirements include: a contemporaneous TP policy updated within three years; a benchmarking study demonstrating arm's-length pricing using OECD-approved methods (CUP, TNMM, Cost-Plus, or Profit Split); and financial adjustments where actual margins fall outside the arm's-length interquartile range.
Critical: downward adjustments reducing taxable income require prior FTA approval. All TP documentation must be ready for FTA review within 30 days of request. Businesses with related-party transactions exceeding AED 40 million must prepare a full Local File.
SAE's tax team assists with TP policy development, benchmarking studies, and disclosure preparation as part of the CT return filing process.
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Our insights are written by ex-Big Four chartered accountants with deep UAE tax and accounting expertise. All content reflects current FTA regulations and legislation.
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