In the UAE, the central transfer pricing filing deadline is tied to the Corporate Tax return. The Transfer Pricing Disclosure Form is submitted together with the annual Corporate Tax return, which is due within nine months of the end of the relevant tax period. For a business with a 31 December financial year end, that translates into a 30 September deadline in the following year. The Master File and Local File have no fixed submission date; they must be produced within 30 days of a request from the Federal Tax Authority (FTA). The rest of this guide unpacks each of these timelines, the thresholds that decide which ones apply to your business, and the regulations behind them.
The core rule: nine months after your tax period ends
Transfer pricing in the UAE sits inside the Corporate Tax regime introduced by Federal Decree-Law No. 47 of 2022, which took effect on 1 June 2023. Under that law, a taxable person must file its Corporate Tax return with the FTA no later than nine months from the end of the relevant tax period, and the transfer pricing information is filed as part of that same return.
Because the deadline is measured from your own financial year end rather than a single national date, the exact day differs from business to business. The most common pattern is a calendar financial year:
- Tax period 1 January 2024 to 31 December 2024: return and Disclosure Form due by 30 September 2025.
- Tax period 1 January 2025 to 31 December 2025: return and Disclosure Form due by 30 September 2026.
- A business with a 30 June year end would instead file by 31 March of the following year.
The simple takeaway: find your financial year end, add nine months, and that is your transfer pricing filing deadline.
What you actually file, and when
UAE transfer pricing compliance is not a single document with a single date. It is layered, and each layer has its own trigger and its own timing. Treating the Disclosure Form as the whole picture is one of the most common and most-costly mistakes.
1. The Transfer Pricing Disclosure Form
This form is filed alongside the Corporate Tax return, so it inherits the nine-month deadline. It captures your related party and connected person transactions and confirms whether they were priced at arm’s length. It is completed within the EmaraTax portal as part of the return, not as a separate submission.
2. The Master File and Local File
These are the detailed documentation files. Critically, they are not filed with your return and have no annual due date. Under Article 55 of the Corporate Tax Law, the FTA may request them at any time, and once it does you have 30 days to submit them. Thirty days is not enough time to build a defensible file from scratch, which is why these documents are expected to be prepared contemporaneously, meaning they exist at the time the transactions take place rather than being reconstructed after a request lands.
3. Country-by-Country Reporting
For the largest groups, a separate Country-by-Country Report (CbCR) and notification apply. This obligation is filed independently of the Corporate Tax return, with the report generally due within 12 months of the end of the reporting fiscal year and the notification due earlier. It affects only UAE-headquartered multinational groups above the AED 3.15 billion revenue threshold.
The thresholds that decide which deadlines apply to you
Whether a given deadline is relevant to your business depends on thresholds set out in the Corporate Tax Law and in Ministerial Decision No. 97 of 2023. The table below summarises the main obligations, who they apply to, and when each is due.
| Obligation | Who it applies to (threshold) | Deadline |
| TP Disclosure Form (Related Party schedule) | Aggregate related party transactions above AED 40 million; then each category above AED 4 million must be broken out | Filed with the Corporate Tax return, within 9 months of the tax period end |
| TP Disclosure Form (Connected Persons schedule) | Aggregate payment or benefit to a single connected person (with related parties) above AED 500,000 | Filed with the Corporate Tax return, within 9 months of the tax period end |
| Master File and Local File | Revenue of AED 200 million or more, or a member of an MNE group with consolidated revenue of AED 3.15 billion or more | Not filed on a fixed date; provided within 30 days of an FTA request |
| Country-by-Country Report and notification | UAE-headquartered MNE group with consolidated revenue above AED 3.15 billion | Report generally due within 12 months of the reporting year end; notification earlier |
Note: the AED 200 million and AED 3.15 billion figures test the size of the entity or group and decide who must maintain full documentation. The AED 40 million, AED 4 million and AED 500,000 figures test the size of the dealings and decide what goes on the Disclosure Form. A business can cross one set of thresholds while sitting below the other, so both need to be checked separately.
The regulations and FTA context behind the deadlines
The UAE transfer pricing framework is deliberately aligned with the OECD Transfer Pricing Guidelines. The key instruments are:
- Federal Decree-Law No. 47 of 2022: The Corporate Tax Law. Articles 34, 35 and 36 cover the arm’s length principle, related parties and connected persons; Article 55 sets the documentation requirement.
- Ministerial Decision No. 97 of 2023: specifies when the Master File and Local File must be maintained.
- FTA Transfer Pricing Guide, issued on 23 October 2023: the FTA’s detailed interpretation of the rules.
- FTA Corporate Tax Guide for Tax Returns, issued in November 2024: clarifies how the Disclosure Form schedules for related parties and connected persons are completed.
All of this is administered through the FTA’s EmaraTax platform, where registration, returns and the Disclosure Form are handled.
The one obligation with no deadline: the arm’s length principle
A crucial point that thresholds can obscure: under Article 34, the arm’s length principle applies to every related party and connected person transaction, regardless of value. Falling below the AED 40 million or AED 500,000 disclosure thresholds means you may not have to complete a schedule, but it does not mean your intercompany pricing is exempt from scrutiny. Prices still have to be defensible, and the FTA can still challenge them.
What happens if you miss a deadline?
Late or inaccurate filing carries administrative penalties under Cabinet Decision No. 75 of 2023. Beyond the direct penalties, weak or missing transfer pricing documentation invites transfer pricing adjustments, additional tax and interest, and it tends to trigger deeper FTA scrutiny across future years. Because assessments can reach back to the start of the relevant financial year, a single gap can affect more than one return.
There is also a records dimension: transfer pricing documentation should be retained for seven years, so a file prepared for 2024 needs to be kept through 2030.
A worked timeline for a December year-end business
Putting it together for the most common scenario, a company whose financial year runs to 31 December 2025:
- Throughout 2025: prepare Master File and Local File contemporaneously if revenue is AED 200 million or more, or the group is above AED 3.15 billion.
- By 30 September 2026: file the Corporate Tax return with the Transfer Pricing Disclosure Form included.
- If the FTA requests documentation: submit the Master File and Local File within 30 days of that request.
- Retain all documentation until at least 2032.
How BCL Globiz helps UAE businesses stay ahead of the deadline
BCL Globiz is a UAE-based professional services firm, part of the BCL Group and a member of IR Global, with a dedicated transfer pricing team supporting businesses from startups to multinationals. The firm works to OECD-compliant methodologies and uses tier-one global benchmarking databases to build defensible transfer pricing positions.
Practical support covers the full compliance cycle:
- Mapping related party and connected person transactions and testing them against the correct UAE thresholds.
- Preparing and filing the Transfer Pricing Disclosure Form with your Corporate Tax return.
- Building the Master File and Local File in advance, so a 30-day FTA request is a routine hand-over rather than a scramble.
- Benchmarking studies and comparability analysis to defend disclosed values.
- CbCR notification and reporting support for larger groups.
You can explore the firm’s full transfer pricing offering here: BCL Globiz Transfer Pricing Services.
Frequently asked questions
When is the transfer pricing Disclosure Form due in the UAE?
It is due with your Corporate Tax return, within nine months of the end of your tax period. For a 31 December year end that is 30 September of the following year.
Do I have to file the Master File and Local File every year?
They are not filed on a set date. You maintain them and submit them within 30 days if the FTA requests them, provided you meet the AED 200 million entity or AED 3.15 billion group threshold.
What if my related party transactions are below AED 40 million?
You may not need to complete the related party schedule, but the arm’s length principle still applies to every transaction and the FTA can still review your pricing.
