Who Needs to Maintain Transfer Pricing Documentation in the UAE?

27 Jul 2026

Transfer pricing UAE refers to the pricing of transactions between related parties to ensure they comply with the arm’s length principle under UAE Corporate Tax law.

Key compliance points:

Applies to related party and connected person transactions UAE
Transactions must be conducted at arm's length, reflecting conditions that would apply between independent parties.
Payments or benefits provided to Related Parties and Connected Persons must comply with the arm’s length principle and satisfy the conditions prescribed under the UAE Corporate Tax Law to be deductible.
Businesses must maintain sufficient records to support their Transfer Pricing positions, regardless of thresholds. The obligation to prepare a Master File and Local File applies only where the prescribed criteria under Ministerial Decision No. 97 of 2023 are met.
Supports transparency and helps prevent artificial profit shifting, aligning with the UAE Corporate Tax regime and the OECD Transfer Pricing Guidelines.

Which law governs transfer pricing UAE documentation requirements?

Transfer pricing obligations in the UAE are governed by a structured federal legal framework supported by ministerial rules.

Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (Corporate Tax Law), as amended by Federal Decree-Law No. 60 of 2023.

This is the primary legislation governing corporate tax and transfer pricing UAE compliance in the UAE, establishing the legal foundation for arm’s length pricing and related party transaction rules.

Key provisions:

Requires application of the arm’s length principle for related party transactions UAE
Mandates maintenance of UAE transfer pricing documentation requirements
Provides legal basis for OECD transfer pricing UAE alignment
Empowers the Federal Tax Authority for assessment and enforcement

Ministerial Decision No. 97 of 2023 (Transfer Pricing Documentation Rules)

This decision defines the operational framework for maintaining transfer pricing documentation in the UAE.

Key requirements:

Master file and local file UAE corporate tax structure
Applicability thresholds for compliance
Contemporaneous documentation requirement
Disclosure of related party transactions UAE

The Explicit Financial Thresholds

Ministerial Decision No. 97 of 2023 sets out the thresholds for determining when a UAE business is required to prepare and maintain transfer pricing documentation. Businesses meeting the relevant criteria must maintain appropriate transfer pricing records, including a Master File and Local File:

Master File and Local File Thresholds: A taxable person is required to maintain both a Master File and a Local File if it meets either of the following thresholds during the relevant tax period:
- The taxable person's standalone revenue is AED 200 million or more; or
- The taxable person is a constituent entity of a Multinational Enterprise (MNE) Group with consolidated group revenue of AED 3.15 billion or more in the relevant financial year.

Important: Even where a taxable person does not meet the above documentation thresholds, all Related Party and applicable Connected Person transactions must still be conducted in accordance with the arm's length principle and sufficient records should be maintained to demonstrate compliance if requested by the Federal Tax Authority (FTA).

Domestic-Only Exception: Certain groups operating exclusively within the UAE may not be required to prepare a Master File, as the Master File requirement is primarily intended for multinational enterprise (MNE) groups. However, where the taxable person meets the transfer pricing documentation thresholds prescribed under Ministerial Decision No. 97 of 2023, it may still be required to maintain a Local File and comply with other transfer pricing documentation obligations.

Who needs to maintain transfer pricing UAE documentation requirements?

Taxable persons required to maintain transfer pricing documentation include businesses engaged in controlled transactions under UAE Corporate Tax rules.

Applicable entities:

Multinational Enterprises (MNEs) operating in the UAE
Companies undertaking cross-border transactions
Taxable persons entering into transactions with related parties
UAE entities transacting with connected persons, where the Corporate Tax provisions apply
Free Zone Persons, including Qualifying Free Zone Persons (QFZPs), where they undertake transactions with Related Parties or Connected Persons.
UAE branches of foreign companies subject to the UAE Corporate Tax Law.

Compliance triggers:

Intercompany services and management fees
Cross-border financing arrangements, including intercompany loans and guarantees
Intellectual property licensing and royalty arrangements
Business restructuring transactions
Cost Contribution Arrangements (CCAs)
Other transactions between Related Parties or Connected Persons that are subject to the arm's length principle.

The Transfer Pricing Disclosure Form (TPDF)

Besides the Master File and Local File, there is a third compliance layer that accompanies the annual Corporate Tax Return, which must be filed within nine (9) months from the end of the relevant taxable period. Under the FTA's reporting requirements, the Transfer Pricing Disclosure Form is generally triggered based on the prescribed materiality thresholds.

Total aggregate related-party transactions exceeding AED 40 million, or
Any single transactional category (e.g., goods, services, financing, IP) exceeding AED 4 million.

Timeline Deadlines

The text states that documentation should be "contemporaneous," but it should explicitly highlight the 30-day rule. Once the Federal Tax Authority (FTA) formally requests your Master or Local file, you have exactly 30 days to submit it. Documentation should therefore be maintained contemporaneously rather than prepared only after an FTA request.

What are UAE transfer pricing documentation requirements under OECD rules?

The UAE follows OECD-aligned transfer pricing principles to ensure international tax consistency.

Key documentation structure:

Master File: Global group structure and policies
Local File: UAE-specific transaction details
Benchmarking analysis for pricing validation
Functional and risk analysis documentation

Compliance features:

Ensures transparency of multinational operations
Aligns with OECD transfer pricing UAE rules
Supports audit readiness under corporate tax UAE compliance
Mandatory under Ministerial Decision No. 97 of 2023

Which transactions fall under related party transactions UAE rules?

Related party transactions form the primary trigger for transfer pricing UAE compliance.

Covered transactions:

Intercompany sale of goods and services
Group financing and loans
Intellectual property licensing
Shared services arrangements
Cost-sharing agreements

Key rule:

All transactions must comply with arm’s length pricing standards under UAE Corporate Tax Law

What are transfer pricing services UAE businesses typically require?

Transfer pricing services UAE support businesses in maintaining compliance and reducing audit exposure.

Key services include:

Master file and local file preparation
Benchmarking and economic analysis
OECD compliance reviews
Risk assessment of intercompany pricing
Audit support during FTA reviews

Business benefits:

Improves corporate tax UAE compliance
Reduces penalty risk
Ensures documentation readiness

What are penalties for non-compliance in transfer pricing UAE rules?

Non-compliance with transfer pricing rules can result in financial and regulatory consequences.

Potential outcomes:

Corporate tax adjustments by Federal Tax Authority
Administrative penalties for missing documentation
Disallowance of non-arm’s length deductions
Increased audit scrutiny
Reputational risks for multinational groups

Compliance importance:

Ensures accurate taxable income reporting
Reduces regulatory exposure
Strengthens audit defensibility

UAE Transfer Pricing Compliance Tier List

Conclusion: Why transfer pricing UAE compliance is essential for businesses

Transfer pricing compliance is a mandatory requirement under UAE Corporate Tax law and plays a critical role in ensuring tax transparency and regulatory alignment.

At AMCA, we provide structured and reliable compliance support tailored to UAE Corporate Tax and OECD transfer pricing standards.

Strengthen your UAE tax position with AMCA Advisory’s Transfer Pricing expertise, including:

Building a robust Transfer Pricing framework aligned with UAE Corporate Tax requirements
Assessing Related Party and Connected Person transactions for compliance risks
Developing defensible Master File and Local File documentation strategies
Advising on tax-efficient group structures and intercompany arrangements
Supporting businesses with ongoing Corporate Tax compliance and regulatory readiness

Stay prepared for FTA scrutiny with reliable Transfer Pricing and Corporate Tax guidance from AMCA. Connect with our experts today.

FAQs on transfer pricing UAE

1. Who must comply with transfer pricing UAE documentation rules?

Multinational Enterprise (MNE) groups operating in the UAE
Taxable persons entering into Related Party or Connected Person transactions
Businesses subject to the UAE Corporate Tax regime

Eligible taxable persons engaging in controlled transactions must comply with the arm’s length principle. Master File and Local File requirements apply only where the documentation thresholds prescribed under Ministerial Decision No. 97 of 2023 are met.

2. What is included in UAE transfer pricing documentation requirements?

Key components

Master File
Local File
Comparability analysis

These documentation requirements support compliance with UAE Corporate Tax Transfer Pricing rules aligned with the OECD Transfer Pricing Guidelines.

3. Is transfer pricing applicable to domestic transactions in UAE?

Yes, if related parties are involved.

Domestic transactions must still comply with:

Arm’s length principle
UAE Corporate Tax documentation rules
OECD transfer pricing standards

4. Why does UAE follow OECD transfer pricing rules?

The OECD framework ensures:

Global tax consistency
Prevention of profit shifting
Standardized compliance structure

UAE has adopted OECD principles under its Corporate Tax regime.

5. How can businesses ensure compliance with UAE transfer pricing rules?

Businesses should maintain:

Contemporaneous Transfer Pricing documentation
Benchmarking studies, where applicable
Intercompany agreements and supporting contractual records
Relevant financial records and transaction details
Professional Transfer Pricing advice, where required

Maintaining proper records and applying appropriate Transfer Pricing policies helps businesses demonstrate compliance with the UAE Corporate Tax Law and manage potential FTA review risks.

Who Needs to Maintain Transfer Pricing Documentation in the UAE? | transfer pricing UAE Guide[