Tax and accounting paperwork on a desk
Guide · Corporate tax

Transfer pricing in the UAE: rules, thresholds and documents

Transfer pricing in the UAE means pricing deals between related businesses as if they were independent. Article 34 of Federal Decree-Law No. 47 of 2022 requires related-party deals to meet the arm's length standard, using one or a combination of five listed methods, or another where none can reasonably apply. With such transactions and revenue of AED 200 million or more, or multinational group revenue of AED 3.15 billion or more, you must keep a local file and, in most cases, a master file.

Global Sky PRO teamUpdated 13 November 20264 min read

Key takeaways

  • Article 34 of the corporate tax law requires transactions between related parties to meet the arm's length standard, whether the other party is onshore, in a free zone or abroad.
  • Payments to connected persons, such as owners and directors, are deductible only up to market value (Article 36), with exceptions for listed and regulated companies.
  • With related-party transactions, Ministerial Decision No. 97 of 2023 requires a local file, and usually a master file, from AED 200 million of revenue or AED 3.15 billion of multinational group revenue in the tax period.
  • Unless you claim small business relief, you must hand over transfer pricing documents within 30 days of an FTA request, or by a later date it sets (Article 55).
  • Qualifying free zone persons must comply with Articles 34 and 55; small business relief claimants skip Article 55 but, says the FTA, still price at arm's length.

What transfer pricing means under UAE corporate tax

Transfer pricing is the price one business charges a related business, such as a sister company, for goods, services, loans or assets. Under Article 34 of Federal Decree-Law No. 47 of 2022, that deal meets the arm's length standard if its results match what unrelated persons would have agreed in similar circumstances. If not, the FTA adjusts your taxable income and makes a matching adjustment for the related party.

The UAE's transfer pricing regulations are Articles 34 to 36 and 55 of that law and Ministerial Decision No. 97 of 2023 on documentation, for tax periods starting on or after 1 June 2023 (Article 69). The FTA's Transfer Pricing Guide (CTGTP1, October 2023) sets out the UAE's transfer pricing guidelines. The FTA says the rules cover dealings onshore, in free zones and abroad, including intra-group loans. Later amendments, up to Federal Decree-Law No. 28 of 2025, left Articles 34, 35, 36 and 55 unchanged.

From Federal Decree-Law No. 47 of 2022 as amended, checked 13 November 2026.
GroupWho it includesRule
Related parties (Article 35)Relatives to the fourth degree; a person and a company they own 50% or more of, or control; companies under common ownership or control; a business and its permanent establishment; partners in one unincorporated partnership; trust and foundation partiesTransactions must be at arm's length (Article 34)
Connected persons (Article 36)Your owners, directors and officers, and their related partiesPayments are deductible only up to market value, and only if incurred wholly and exclusively for your business

Control means 50% or more of the votes, board or profits, or significant influence over the business. The connected person rule doesn't apply to companies listed on a recognised stock exchange or under a UAE regulator's oversight. Running a holding company? Its fees and loans to group companies fall under these rules.

The five transfer pricing methods

Article 34(3) lists five methods, which the FTA's guide calls internationally accepted:

  • Comparable uncontrolled price. Compares your price with one agreed between independent parties.
  • Resale price. Works back from the price at which goods are resold to an independent buyer.
  • Cost plus. Adds an arm's length mark-up to the supplier's costs.
  • Transactional net margin. Compares your net profit with that of comparable independent transactions.
  • Transactional profit split. Splits combined profits as independent parties would.

Pick the most reliable method, considering contract terms, the transaction's features, economic circumstances, functions, assets and risks, and business strategies. Another method is allowed only if none of the five can reasonably apply. The FTA's guide draws on the January 2022 OECD guidelines; it isn't legally binding and may change, so check the current version.

Thresholds and documents

From Federal Decree-Law No. 47 of 2022 and Ministerial Decision No. 97 of 2023, checked 13 November 2026.
RequirementWho it applies toSource
Arm's length pricingEvery taxable person dealing with related parties or connected personsArticles 34 and 36
Disclosure filed with the tax returnTaxable persons the FTA requires, in the form it setsArticle 55(1)
Master file and local fileTaxable persons with related-party or connected-person transactions and revenue of AED 200 million or more in the tax period, or in a multinational group with consolidated revenue of AED 3.15 billion or moreArticle 55(2) and Ministerial Decision No. 97 of 2023
Documents on requestAny taxable person the FTA asks, except small business relief claimants: within 30 days, or a later date it setsArticle 55(3) and (4); Article 21(2)
Record keepingSeven years after the end of the tax periodArticle 56

The FTA's guide says companies in a UAE-only group need only the local file. The local file covers transactions with non-residents, exempt persons, residents claiming small business relief and residents taxed at a different rate, such as a qualifying free zone person. It leaves out other residents taxed at your rate and natural persons acting independently. Below the thresholds, the FTA's guide still expects reasonable records.

The FTA decides when the return's transfer pricing disclosure is needed; ask your tax agent to confirm whether yours needs one before you file.

Free zone companies and small business relief

A qualifying free zone person must comply with Articles 34 and 55 to keep its status (Article 18(1)(d)); the FTA lists "comply with transfer pricing rules and maintain the relevant transfer pricing documentation" among the conditions.

Small business relief is different. Article 21(2) switches off Article 55, so claimants skip the documentation rules, but the FTA's Transfer Pricing Guide says they still need arm's length pricing. On 7 August 2026 the Ministry of Finance extended the relief to tax periods ending on or before 31 December 2029, for revenue not exceeding AED 3 million. See common tax mistakes new companies make.

Transfer pricing compliance checklist

  • 1. Map your related parties and connected persons using Articles 35 and 36.
  • 2. List every transaction with them: sales, services, loans, fees and payments to owners or directors.
  • 3. Check the Ministerial Decision No. 97 thresholds for each tax period.
  • 4. Price at arm's length and keep records supporting the method; a registered tax agent can prepare the analysis.
  • 5. Complete any disclosure the FTA requires with your corporate tax return.
  • 6. Keep records for seven years and be ready to produce them within 30 days.

Global Sky PRO isn't a tax agent or auditor and doesn't prepare transfer pricing studies or give tax advice. Use a registered tax agent for studies and filings; see how to choose a tax agent. We handle corporate tax registration paperwork and document preparation; read how to register for corporate tax.

FAQs

Questions about this topic

Short answers here. Your situation may differ, so ask us before you decide.

Still have a question?

An adviser replies during opening hours, Mon–Sat 10:00–21:00.

Ask on WhatsApp
What is transfer pricing in the UAE?

It's the rule that transactions between related parties must be priced as if the parties were independent. Article 34 of Federal Decree-Law No. 47 of 2022 calls this the arm's length standard.

Source: Ministry of Finance: Federal Decree-Law No. 47 of 2022 and its amendments

Do transfer pricing rules apply to transactions inside the UAE?

Yes. The FTA says the rules apply to transactions with related parties and connected persons whether they are onshore, in a free zone or abroad.

Source: FTA: Corporate tax FAQ on transfer pricing

What is the transfer pricing documentation threshold in the UAE?

If you have related-party or connected-person transactions, Ministerial Decision No. 97 of 2023 requires a local file and master file when your revenue in the tax period is AED 200 million or more, or your multinational group's consolidated revenue is AED 3.15 billion or more. The FTA's guide says companies in a UAE-only group need only the local file.

Source: Ministry of Finance: Ministerial Decision No. 97 of 2023

Do I file the master file and local file with my tax return?

Article 55 says you maintain them and submit them within 30 days of an FTA request, or by a later date it sets. What goes with the return is the transfer pricing disclosure, where the FTA requires it.

Source: Ministry of Finance: Federal Decree-Law No. 47 of 2022 and its amendments

Who is a related party under UAE corporate tax?

Article 35 covers relatives to the fourth degree, a person and a company they own 50% or more of, or control, companies under common control, a business and its permanent establishment, partners in the same unincorporated partnership, and trust or foundation parties.

Source: Ministry of Finance: Federal Decree-Law No. 47 of 2022 and its amendments

What is a connected person?

Under Article 36, it's an owner, director or officer of the taxable person, or a related party of one of them. Payments to them are deductible only up to market value, except for listed or regulated companies.

Source: Ministry of Finance: Federal Decree-Law No. 47 of 2022 and its amendments

Which transfer pricing methods does the FTA accept?

Article 34(3) lists comparable uncontrolled price, resale price, cost plus, transactional net margin and transactional profit split. Article 34(4) allows another method only if none of these can reasonably be applied.

Source: Ministry of Finance: Federal Decree-Law No. 47 of 2022 and its amendments

Do free zone companies need transfer pricing documentation?

A qualifying free zone person must comply with Articles 34 and 55, and the FTA lists maintaining the relevant transfer pricing documentation among the conditions for the status. Master and local files are needed only above the Ministerial Decision No. 97 thresholds (Article 55(2)).

Source: FTA: Corporate tax FAQ on transfer pricing

Does small business relief remove transfer pricing obligations?

Only the documentation part. Article 21(2) disapplies Article 55, but the FTA's Transfer Pricing Guide says claimants still need arm's length pricing for related-party transactions.

Source: FTA: Transfer Pricing Guide (CTGTP1)

Do transactions within a tax group need transfer pricing?

Generally not, because the FTA says transactions between tax group members are eliminated on consolidation. They matter again when a member's stand-alone taxable income is needed, such as when it leaves the group.

Source: FTA: Corporate tax FAQ on transfer pricing

How long must I keep transfer pricing records?

Article 56 requires taxable persons to keep records and documents for seven years after the end of the tax period.

Source: Ministry of Finance: Federal Decree-Law No. 47 of 2022 and its amendments

Can Global Sky PRO prepare my transfer pricing study?

No. We aren't a tax agent or auditor; a registered tax agent should prepare studies and filings. We help with corporate tax registration paperwork and document preparation.

Get started

Want us to check your case?

Send a few details and we'll reply with the route, the documents and every fee involved.

Send your enquiry

Takes a minute. We reply with the next steps and every fee involved.