Understanding the UAE TP Disclosure Form – Don’t Miss These Essentials

With the introduction of UAE Transfer Pricing (TP) regulations under Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses—along with accompanying Ministerial and Cabinet Decisions—UAE businesses are now required to comply with TP rules for tax periods beginning on or after 1 June 2023.

 Here's why TP matters in the UAE

🎯 1. Ensures Compliance with Corporate Tax Law

Transfer pricing is a legal requirement under the UAE Corporate Tax Law to ensure that transactions between related parties and connected persons are conducted at arm’s length—i.e., as if between unrelated parties.

 Failure to comply can lead to:

 • Tax adjustments

• Penalties

• Audit scrutiny

 🌍 2. Aligns UAE with International Standards (OECD)

The UAE has committed to implementing the OECD BEPS (Base Erosion and Profit Shifting) framework as a member of the OECD Inclusive Framework. Transfer Pricing (TP) regulations help to:

 • Prevent profit shifting to low- or no-tax jurisdictions

• Support fair taxation across borders

• Attract foreign investment by aligning with global standards.

🎯 Why TP is Important in the UAE

Here’s what your business needs to know to stay compliant and competitive.

🎯  ARM’S Length Principle (ALP)

The arm’s length principle ensures that transactions between Related Parties or Connected Persons are priced as if they were between independent entities under comparable circumstances. This is central to UAE Transfer Pricing regulations under Federal Decree-Law No. 47 of 2022.

To determine whether a transaction complies with the ALP, the UAE law prescribes five OECD-aligned methods:

🎯Application of Methods_ Transaction-Wise Analysis

🎯  Connected Persons

Under the UAE Corporate Tax Law (Federal Decree-Law No. 47 of 2022), a Connected Person is a specific category of individual or entity that has a special relationship with the taxable business, primarily to prevent profit shifting through non-arm’s-length transactions.

🎯 Examples of Connected Persons

🎯 Related Parties

Related parties include any associated Persons, according to a specified degree of association. This association refers to a pre-existing relationship with another Person through kinship (in the case of natural persons), ownership, or Control, regardless of whether that other Person is a resident or not in the UAE.

🎯Transfer Pricing compliance requirements in the UAE:

Below is a summary of the UAE Transfer Pricing (TP) compliance requirements, their applicability, and the corresponding deadlines:

🎯   📄 Transfer Pricing Disclosure Form (TPDF)

 Below is the UAE CT return - TP Disclosure form- Connected Person

🎯Below is the UAE CT return - TP Disclosure form- Related parties

🎯📘 Master File & Local File

The requirement to prepare and maintain the Master File and Local File applies to Taxable Persons who meet either of the following conditions during the relevant Tax Period:

· The Taxable Person is a Constituent Entity of a Multinational Enterprise (MNE) Group with consolidated group revenue of AED 3.15 billion or more, or

.The Taxable Person's individual revenue is AED 200 million or more

Both files must be prepared on a contemporaneous basis and made available to the Federal Tax Authority (FTA) upon request, typically within 30 days.

📌Local File - The Local File focuses on the UAE entity's specific transactions with related parties, explaining the nature of these dealings and showing that prices are set fairly, as if between independent companies.

📌Master File- The Master File gives an overview of the entire multinational group, including its structure, global operations, and transfer pricing policies.

🎯   🌍 Country-by-Country Reporting (CbCR)

 Country-by-Country Reporting (CbCR) is applicable to Multinational Enterprise (MNE) Groups that are headquartered in the UAE and have consolidated group revenue equal to or exceeding AED 3.15 billion (approximately EUR 750 million) during the fiscal year immediately preceding the reporting fiscal year. This must be submitted within 12 months from the end of the relevant fiscal year.

As the UAE continues to align with international tax standards, Transfer Pricing compliance has become a critical component of corporate tax obligations. Understanding the key requirements—such as the Transfer Pricing Disclosure Form, Master and Local Files, and Country-by-Country Reporting—is essential for businesses to mitigate tax risks and ensure regulatory compliance. Proactive documentation, timely filings, and alignment with the Arm’s Length Principle will help businesses navigate the evolving tax landscape with confidence and clarity.

🎥 Want to Learn More? Watch Our TP Webinars

For a deeper dive into UAE Transfer Pricing compliance—covering practical examples, documentation strategies, and FTA expectations—watch our recorded webinars on Transfer Pricing under the UAE Corporate Tax Law.

YouTube link_ TP complete recorded webinar info.

1.     Connected person       https://youtu.be/BUiOI5lXGjU

2.     TP Compliance           https://youtu.be/--3jbvVgCs0

3.     FAR Analysis             https://youtu.be/_GRp7yvb0k4

4.     TP basics                     https://youtu.be/jXp64NpnucA

📚 Interested in Learning About UAE Tax Return Filing?

Stay ahead of compliance requirements with our comprehensive UAE Corporate Tax Return Filing Course — designed for finance professionals, tax advisors, and business owners navigating the new UAE tax regime.

1.     UAE corporate tax law: A complete guide to compliance and filing –https://www.udemy.com/course/uae-corporate-tax-law/?couponCode=55960A77B380BF80EEB6

2.     UAE corporate tax return filing – A step-by-step approach - https://www.udemy.com/course/uae-corporate-tax-return-filing

“Key Takeaways & Next Steps”

Understanding and accurately completing the UAE TP Disclosure Form isn’t just a regulatory requirement—it’s a critical part of demonstrating tax transparency and avoiding costly non-compliance issues. As the UAE continues to align with OECD standards, staying ahead of your transfer pricing obligations is not optional—it’s essential.

💡 Have you started preparing for this year’s disclosure? 📌 Whether you're a CFO, tax advisor, or finance manager, early action can save you from last-minute stress and penalties.

👉 If you found this article helpful like it to support more tax transparency content. 🔁 Share it with your network—someone in your industry might need this reminder. 💬 Have questions or insights on UAE TP compliance? Drop them in the comments—let’s start a conversation.

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