Transfer Pricing compliance overview of UAE

Executive Summary

General Requirements

  • Transfer pricing regulations are integrated within the Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses.
  • The arm’s length principle serves as the foundational standard for transactions between related parties and connected persons.
  • Compliance obligations apply to both international and domestic transactions.
  • Taxable persons are required to determine arm’s length values at the time the controlled transaction is undertaken or by the time the tax return is filed.

Documentation Requirements

  • The Federal Tax Authority mandates a three-tiered documentation approach, consisting of a Master File, a Local File, and a Country-by-Country (CbC) Report.
  • All taxable persons engaging in transactions with related parties or connected persons must submit a Transfer Pricing Disclosure Form alongside their annual tax return.
  • Documentation must be contemporaneously maintained and is expected to be prepared in the English language.
  • Qualitative records such as benchmarking studies, functional analyses, and intercompany agreements are required to substantiate the arm’s length nature of dealings.

Results of Non-Compliance

  • Failure to maintain required transfer pricing documentation for a period of five years results in a fixed administrative penalty of AED 100,000.
  • Late filing of a Country-by-Country Report can trigger substantial fines up to AED 1,000,000 plus daily penalties of AED 10,000.
  • Inaccurate or incomplete CbC reporting is subject to specific administrative fines ranging from AED 50,000 to AED 500,000.
  • The tax authority is empowered to adjust taxable income to reflect arm’s length outcomes, which may lead to secondary adjustments and additional interest on overdue payments.

Country Specific Information

  • Domestic organisations headquartered in the UAE with no commercial premises abroad are exempt from maintaining a Master File.
  • Organizations categorized as UAE-headquartered must still maintain a Local File if they meet the specific individual revenue thresholds.
  • The mandatory Transfer Pricing Disclosure Form serves as a primary risk assessment tool for the tax authority to select candidates for audit.
  • Article 36 of the Corporate Tax Law imposes specific scrutiny on payments to “Connected Persons” to ensure they are wholly and exclusively for business purposes.

Compliance Table

DocumentDeadlineLanguageThresholds, Scope & Penalties
Local FileMaintained by return date (9 months post-FY); submitted within 30 days of request.English.Mandatory if individual revenue $\ge$ AED 200m or group consolidated revenue $\ge$ AED 3.15bn. Applies to domestic and cross-border transactions. Penalty: AED 100,000 for failure to maintain records.
Master FileMaintained by return date (9 months post-FY); submitted within 30 days of request.English.Mandatory for constituent companies of MNE groups with consolidated revenue $\ge$ AED 3.15bn or where entity revenue $\ge$ AED 200m. Exempts UAE-only headquartered groups. AED 100,000 record-keeping penalty.
CbC NotificationNo later than the last day of the reporting fiscal year.English.Required for all constituent entities of groups with consolidated revenue $\ge$ AED 3.15bn. Penalties as per Tax Procedures Law.
CbC ReportWithin 12 months after the last day of the reporting fiscal year.English.Mandatory for UAE-resident UPEs of groups with consolidated revenue $\ge$ AED 3.15bn. Penalty: Up to AED 1m plus AED 10k/day for late filing.
TP Disclosure FormSubmitted alongside the tax return (within 9 months post-FY).English.Mandatory for all taxable persons conducting transactions with related parties or connected persons. Thresholds for form proposed but not yet prescribed.

Disclaimer: This information is obtained from secondary sources and is included for informative purposes. It should be confirmed by a local advisor.