Linkedin
Facebook
Email
more
UAE Transfer Pricing Services
UAE transfer pricing, mapped to your related-party transactions
The UAE Corporate Tax Law brings transactions with related parties and connected persons under the arm's length principle, for domestic and cross-border dealings alike. Prices must be supportable, disclosed with the corporate tax return once the thresholds are met, and, for larger businesses, documented in a Master File and Local File that the FTA can request.
RSM UAE's transfer pricing team helps you identify your controlled transactions, set and defend arm's length prices, and prepare the disclosures and documentation that apply to you, drawing on transfer pricing specialists across the RSM network.
Note: the AED 200 million revenue threshold (or AED 3.15 billion consolidated revenue for MNE group members) for Master File and Local File comes from Ministerial Decision No. 97 of 2023. It is a regulatory figure, not an RSM fee or estimate.
Two Transfer Pricing Frames Under UAE Law
Every taxable person with related-party or connected-person transactions must price them at arm's length. What changes with size is how much you have to disclose and document. Frame 1 covers the obligations that apply to every taxable person; Frame 2 adds the Master File and Local File required of larger businesses and groups. The services below are built around what each one requires.
Law
Federal Decree-Law No. 47 of 2022 (Corporate Tax Law), including its arm's length, related party and connected person provisions
Applies to
Any taxable person that transacts with related parties or connected persons, whether in the UAE or abroad
Requires
Arm's length pricing for every controlled transaction · Transfer Pricing Disclosure Form with the corporate tax return where related party transactions exceed AED 40 million (categories above AED 4 million listed) · connected person schedule where transactions exceed AED 500,000
Key dates
Disclosure Form filed with the corporate tax return, within 9 months of the end of the tax period
Consequence
The FTA can adjust prices and taxable income; reducing taxable income through a downward adjustment needs FTA approval
Our services for this frame
■ Mapping of related party and connected person transactions
■ Arm's length benchmarking and method selection
■ Transfer Pricing Disclosure Form preparation
■ Connected person payment reviews
■ Intercompany agreements that match how the business operates
■ Tax group transfer pricing reviews under Ministerial Decision No. 301 of 2025
Law
Ministerial Decision No. 97 of 2023 on the requirements for maintaining transfer pricing documentation
Applies to
Taxpayers with revenue of AED 200 million or more in the tax period, or members of an MNE group with consolidated revenue of AED 3.15 billion or more
Requires
A Master File and Local File maintained for the tax period and provided to the FTA on request (they are not filed with the return) · transfer pricing methods consistent with the Disclosure Form
Key dates
Prepared for each tax period, ideally before the corporate tax return is filed so disclosed positions match
Penalty
Failure to keep required records: AED 10,000 per violation (AED 20,000 if repeated within 24 months) under Cabinet Decision No. 129 of 2025, plus exposure to FTA adjustments
Our services for this frame
■ Master File and Local File preparation
■ Functional analysis and benchmarking studies
■ Transfer pricing policy design and year-end adjustments
■ Alignment with Country-by-Country Reporting and Pillar Two data
■ FTA information requests and audit support
■ Annual documentation updates as the business changes
Build Your UAE Transfer Pricing Compliance Assessment
Start with the checklist for the frame that applies to your business. Anything you can't tick confidently is where an assessment should start.
Frame 1 — Arm's Length & Disclosure
☐ Have you identified all your related parties and connected persons, including owners and directors?
☐ Do you know whether your related party transactions exceed AED 40 million for the Disclosure Form?
☐ Can you show how each controlled transaction was priced at arm's length?
☐ Are payments to connected persons above AED 500,000 identified and supported?
☐ Do written intercompany agreements reflect what actually happens?
☐ Have you reviewed intra-group transactions that need arm's length treatment within a tax group?
☐ Is your transfer pricing method consistent with what you will disclose in the return?
Frame 2 — Master File & Local File
☐ Is your revenue, or your group's consolidated revenue, above the Master File and Local File thresholds?
☐ Do you have a current Master File and Local File for the latest tax period?
☐ Could you provide both files promptly if the FTA asked?
☐ Has a functional analysis been done for your main entities and transactions?
☐ Are your benchmarking studies up to date?
☐ Do year-end results match your transfer pricing policy, with adjustments where needed?
☐ Is your documentation consistent with Country-by-Country Reporting and Pillar Two data?
Why Choose RSM UAE?
RSM UAE combines UAE Corporate Tax knowledge with the transfer pricing experience of the wider RSM network. Expand each reason below.
Let's make sure your related-party pricing stands up before your next return.
Reach our Tax team directly, or send us a message using the enquiry form below.
In order to watch this video please
click here and enable 'Functional Cookies' or select 'Allow all' cookies.
Thank you
In order to listen to this podcast please
click here and enable 'Functional Cookies' or select 'Allow all' cookies.
Thank you
