Transfer Pricing in the UAE: Why It Matters for Corporate Tax Compliance in 2025 and Beyond


With the introduction of federal Corporate Tax effective from financial years starting on or after 1 June 2023, transfer pricing (TP) has become a cornerstone of tax compliance in the UAE. The UAE follows the OECD Transfer Pricing Guidelines and applies the arm’s length principle to transactions between related parties and connected persons.

Key Transfer Pricing Requirements

  • Maintain a Transfer Pricing Disclosure form along with the Corporate Tax return.
  • Prepare Local File and Master File documentation if the consolidated group revenue exceeds AED 3.15 billion (Master File) or if related-party transactions exceed AED 50 million (Local File).
  • Submit Country-by-Country Report (CbCR) if global consolidated revenue exceeds AED 3.15 billion.

Failure to comply can trigger penalties of up to AED 200,000 for documentation non-submission and potential tax adjustments plus interest.

Benefits of a Robust Transfer Pricing Policy

  • Mitigates the risk of double taxation.
  • Enhances transparency with the FTA during audits.
  • Supports tax-efficient group structures.

For an in-depth discussion on transfer pricing obligations and best practices, read the expert analysis published by Tulpar Global Taxation: https://tulpartax.com/importance-of-transfer-pricing-in-uae-tax-compliance/

Tulpar Global Taxation offers comprehensive transfer pricing services, including policy design, documentation preparation, benchmark studies, and advance pricing agreements (APAs) to ensure full compliance and optimal tax positioning