Tax guides · Transfer pricing
UAE transfer pricing guide
Under UAE corporate tax, transactions with related parties and connected persons must be priced as independent parties would price them. If they are not, the FTA can adjust the taxable income. This guide explains who is covered, which transactions to look at and what to keep on file.
What are the key UAE transfer pricing rules?
| Item | Figure | Source |
|---|---|---|
| Arm's length principle | Applies to transactions with related parties and connected persons | Federal Decree-Law No. 47 of 2022, Articles 34 to 36 |
| Free zone entities | Covered; arm's length pricing is also a condition for Qualifying Free Zone Person status | Federal Decree-Law No. 47 of 2022 |
| Related parties | Include individuals related to the fourth degree of kinship or affiliation | Federal Decree-Law No. 47 of 2022, Article 35(1) |
| Disclosure form | Filed with the tax return when the FTA requires it | Federal Decree-Law No. 47 of 2022, Article 55(1) |
| Master file and local file | Required if revenue is AED 200 million or more, or the group's consolidated revenue is AED 3.15 billion or more; provide within 30 days of an FTA request | Federal Decree-Law No. 47 of 2022, Article 55(2) and (3); Ministerial Decision No. 97 of 2023 |
Which related-party transactions need attention?
Who is a related party or connected person?
Related parties include companies under common control, parent and subsidiary companies, and individuals with their relatives up to the fourth degree. Connected persons include the owners, directors and officers of the business and their related parties.
Which transactions usually need attention?
Sales and purchases of goods within the group, management fees and head office charges, shared services, royalties and brand fees, intra-group loans and guarantees, and rent or service fees paid to owners.
What happens if pricing is not at arm's length?
The FTA can adjust the price, and therefore the taxable income, and in a group the other side may not get a matching adjustment. Free zone companies can also put their 0% status at risk.
What should we keep on file?
Signed intercompany agreements, how each price was set, evidence the service was actually provided, and the benchmarking or calculation that supports the margin.
Not sure your intercompany pricing would hold up?
We map your related-party transactions and test the pricing before the FTA asks.
Last reviewed: 22 October 2026 · Reviewed by Muhammad Imran, ACMA
General information only, not legal or tax advice.
Valorin is an independent advisory firm, not affiliated with the FTA or MoF.