Transfer pricing disclosure form in the UAE: what to file and when

What is the transfer pricing disclosure form UAE?

The transfer pricing disclosure form UAE is a schedule filed with the corporate tax return. It reports related party transactions and connected person payments above set thresholds. The Federal Tax Authority (FTA) uses it to assess arm's length pricing under Federal Decree-Law 47 of 2022. It is mandatory for in-scope taxable persons.

This guide explains who files the disclosure, what data goes into it, and how it sits alongside the master file, local file, and Country by Country Report. It is part of our UAE Corporate Tax hub, which covers registration, filing, and compliance for businesses operating in the Emirates.

Why the UAE introduced a disclosure form

The UAE corporate tax regime took effect for financial years starting on or after June 1, 2023. Article 55 of the Corporate Tax Law gives the FTA the power to require transfer pricing information. The disclosure form is the practical tool for that.

It lets the FTA screen large volumes of related party activity quickly. Tax officers can flag mispriced transactions, missing documentation, or risky structures without opening a full audit. For businesses, the form is a yearly checkpoint that forces internal review of intercompany pricing.

Legal basis at a glance

• Federal Decree-Law 47 of 2022, the Corporate Tax Law.
• Articles 34 and 35 on the arm's length principle and related parties.
• Article 55 on transfer pricing documentation duties.
• FTA Transfer Pricing Guide, issued October 2023.
• OECD Transfer Pricing Guidelines, applied by reference.

Who must file the transfer pricing disclosure form

Every taxable person that has related party transactions or connected person payments above the FTA's reporting thresholds must complete the disclosure form. It is submitted as part of the corporate tax return, not as a separate filing. The return is due within 9 months of the end of the tax period.

Qualifying Free Zone Persons (QFZPs) are not exempt. They must still file the disclosure because the arm's length principle applies to all in-scope businesses, including those benefiting from the 0% Free Zone rate.

Thresholds that trigger reporting

The FTA sets monetary thresholds in Ministerial Decisions. The aggregate value of transactions with a category of related parties or connected persons must exceed the threshold before line-by-line reporting kicks in. Below the threshold, the taxpayer still confirms the position on the return, but does not list each transaction.

Check the latest FTA guidance for the exact amounts in your tax period. Thresholds can be updated by Ministerial Decision. See the UAE Transfer Pricing Rules page for the underlying definitions of related party and connected person.

What information goes into the disclosure form

The disclosure form is a structured schedule. It asks for transaction level data for each category that crosses the threshold. The aim is to give the FTA a clear picture of the intercompany footprint, the transfer pricing method used, and the resulting impact on taxable income.

Related party section

For each related party transaction category, the taxpayer reports:

• Name and tax jurisdiction of the counterparty.
• Nature of the transaction, for example management services or loan interest.
• Gross transaction value in AED for the period.
• Transfer pricing method applied, such as CUP, cost plus, or TNMM.
• Arm's length value if it differs from the booked value.
• Any adjustment made to taxable income.

Connected person section

For payments to connected persons, including owners and senior management and their relatives, the taxpayer reports:

• Name and relationship of the connected person.
• Type of payment, such as salary, bonus, or benefit in kind.
• Total value paid during the tax period.
• Whether the payment reflects market value for the services rendered.

Method selection summary

The form expects a method per transaction category. The five OECD methods recognised by the FTA are:

1. Comparable Uncontrolled Price (CUP).
2. Resale Price Method.
3. Cost Plus Method.
4. Transactional Net Margin Method (TNMM).
5. Transactional Profit Split Method.

An "other method" is allowed only when none of the five fits the facts. Justify the choice in the supporting documentation.

How the disclosure form links to other transfer pricing files

The disclosure form is the top layer of UAE transfer pricing reporting. Larger groups face additional documentation requirements. Understanding the stack avoids duplicate work and missed filings.

For deeper coverage of each file, see UAE Transfer Pricing Documentation, Transfer Pricing Master File UAE, Transfer Pricing Local File UAE, and CbCR UAE.

Step by step: preparing the disclosure form

A clean disclosure starts with clean data. The form draws on the trial balance, intercompany ledgers, and payroll records for connected persons. Build a yearly process that maps each source to the form fields.

Step 1: identify related parties and connected persons

Apply the legal definitions in Articles 35 and 36 of the Corporate Tax Law. Related parties include entities under common control of 50% or more. Connected persons include owners, directors, officers, and their relatives within the fourth degree. See Related Party Transactions UAE for the full list.

Step 2: extract intercompany transactions

Pull all intercompany journals for the tax period. Categorise them: goods, services, royalties, interest, financial guarantees, asset transfers, and cost recharges. Convert foreign currency lines to AED at the rates used in the financial statements.

Step 3: test against the arm's length principle

For each category that breaches the threshold, run a benchmark. Use commercial databases or internal comparables. If the booked price falls outside the arm's length range, calculate the adjustment needed.

Step 4: document the method

Record the method selected and why. The FTA expects a written rationale even when the master file and local file are not required. Keep the benchmarking study on file for at least 7 years.

Step 5: complete and submit

Enter the data into the disclosure schedule within the EmaraTax corporate tax return. Cross-check totals against the financial statements. Submit with the return before the 9 month deadline.

Common errors to avoid

The form looks simple, but small mistakes create audit risk. Review your draft against this checklist before submission.

• Missing connected person salaries paid to a sole owner.
• Netting intercompany sales and purchases instead of reporting gross.
• Using the same method for every category without justification.
• Forgetting interest on intercompany loans, including current accounts.
• Excluding QFZP entities on the assumption they are out of scope.
• Reporting in the counterparty's currency rather than AED.
• Failing to update the disclosure after a year end audit adjustment.

Penalties for non-compliance

The FTA can impose administrative penalties for incorrect or missing transfer pricing information. Penalties apply per violation and can stack across categories. The exact amounts are set by Cabinet Decisions on tax procedures and may be updated.

Beyond fixed penalties, the FTA can adjust taxable income upward. That triggers tax at 9% on profits above AED 375,000, plus late payment interest. A QFZP that fails the arm's length test on its qualifying income can lose the 0% rate for 5 years, with profits taxed at 9% instead.

How to reduce penalty risk

1. File the disclosure on time, even if some figures are estimates.
2. Keep a benchmarking study for every material category.
3. Reconcile the form to audited financials and the VAT return.
4. Document board approval of transfer pricing policies.
5. Refresh benchmarks every 3 years, or sooner if the business model changes.

Worked example: a UAE trading company

Consider a Dubai mainland trading company with two related parties: a procurement office in Singapore and a holding company in the Netherlands. The owner also draws a salary and dividends.

The company reports each line on the disclosure form. The inventory purchases are benchmarked against third party trading margins. The loan interest is compared to UAE bank lending rates for similar tenor. The owner's salary is benchmarked against market pay for a managing director in the same sector. Dividends are not in scope of the arm's length test but are still flagged on the connected person schedule.

Aligning the disclosure with other tax filings

The disclosure form does not sit alone. It should match the figures in the financial statements, the VAT returns, and any economic substance filings. Mismatches are a red flag for the FTA.

VAT reconciliation

Related party sales of goods and services usually show up in the VAT returns too. The total intercompany supplies reported across 4 quarterly VAT returns should reconcile to the related party section of the disclosure, after adjusting for out of scope flows.

Financial statements

UAE corporate tax requires IFRS or IFRS for SMEs. The related party note in the financial statements is a useful starting point. Make sure the disclosure form covers every counterparty named there.

Practical timeline for a calendar year taxpayer

For a business with a December 31 year end, the disclosure form is part of the corporate tax return due by September 30 of the following year. Working backwards, a realistic timeline looks like this:

Where to find official guidance

Always start with primary sources before relying on third party commentary. The following links lead directly to the regulators:

• Federal Tax Authority for corporate tax guides and EmaraTax access.
• UAE Ministry of Finance for Cabinet Decisions and Ministerial Decisions.

Bookmark these and check for updates before each filing cycle. Transfer pricing guidance has been refined several times since 2023 and will continue to evolve.

How EInvoice Direct helps finance teams stay audit ready

EInvoice Direct is the UAE e-invoicing platform from Massive FZCO. It captures every B2B (business to business) invoice in PINT AE format and stores structured data that maps cleanly to related party reporting. Finance teams use it to extract intercompany volumes by counterparty for the disclosure form, instead of rebuilding the data from PDFs each year. An accredited service provider is included with the software at no extra charge. To see pricing and onboarding for your group, get UAE e-invoicing pricing from our team. Linking your e-invoicing data to your UAE Corporate Tax workflow shortens close cycles and reduces disclosure errors.