UAE Transfer Pricing Disclosure Form: Complete Guide 2026

Quick summary

• The TP Disclosure Form must be filed where applicable, but the detailed schedules only need to be completed once specific AED thresholds are met.
• It’s filed with your Corporate Tax Return via EmaraTax, due 9 months after your tax period ends.
• The arm’s length principle applies to every related party transaction regardless of value, whether or not it needs to be disclosed.
• Penalties for late or incorrect filing follow the standard Corporate Tax penalty schedule, not a separate TP-specific one.

Transfer Pricing Disclosure Form UAE Overview

Federal Decree-Law No. 47 of 2022, which governs UAE Corporate Tax, requires taxable persons with related party or connected person transactions to submit a Transfer Pricing (TP) Disclosure Form together with their Corporate Tax Return, as set out under Article 55(1) and detailed in the FTA’s guidance. Which schedules of the form must be completed in detail depends on the materiality thresholds covered later in this article.

The Federal Tax Authority’s Corporate Tax Guide for Tax Returns clarifies exactly what the TP Disclosure Form requires: the nature and value of controlled transactions, details of related parties and connected persons, the transfer pricing method applied, and any resulting adjustments. The form is filed through the EmaraTax portal alongside the Corporate Tax Return, which is due within nine months from the end of the relevant tax period. For example, a taxable person with a 31 December 2025 financial year-end has a filing deadline of 30 September 2026.

This article covers who actually needs to file the form, the materiality thresholds that trigger each schedule, the sections of the form itself, the supporting documents required, and the penalties for getting it wrong.

Do You Need to File the TP Disclosure Form (Thresholds)

A common misconception is that crossing a materiality threshold is what triggers the TP Disclosure Form itself. In practice, the form is filed as part of the Corporate Tax Return wherever a taxable person has related party or connected person transactions; what the thresholds below determine is which schedules must actually be completed in detail, not whether the form is filed at all. The arm’s length principle applies to all related party and connected person transactions without exception, regardless of whether the detailed disclosure thresholds are met:

Schedule	Threshold to trigger disclosure
Related Party Transaction (RPT) schedule	Aggregate value of all related party transactions exceeds AED 40 million. Once this primary threshold is crossed, any individual transaction category (goods, services, IP, interest, assets, liabilities, other) exceeding AED 4 million must be separately itemised.
Connected Person (CP) schedule	Aggregate payment or benefit to a single connected person, together with that person’s related parties, exceeds AED 500,000.
Master File and Local File	UAE taxable person’s own revenue is AED 200 million or more in the relevant tax period, or the entity is part of an MNE Group with consolidated group revenue of AED 3.15 billion or more (Ministerial Decision No. 97 of 2023).

These thresholds are independent of one another. A business can fall below the RPT and CP disclosure thresholds and still be required to prepare a Local File if its own revenue exceeds AED 200 million, or vice versa. Falling below all three thresholds does not exempt a business from the arm’s length principle itself; it only removes the formal obligation to disclose the detail on the form or maintain a Master File/Local File in the prescribed format. The FTA can still request supporting analysis for any related party transaction, at any value, and in practice businesses are expected to have some record of how their pricing was determined, even where a formal Local File is not mandatory.

Free Zone Entities and Transfer Pricing

Free zone status does not exempt a business from transfer pricing rules. This is especially important for Qualifying Free Zone Persons (QFZPs), since maintaining the 0% Corporate Tax rate on qualifying income is directly conditional on transfer pricing compliance.

A QFZP must price all transactions with related parties at arm’s length, including intra-group transactions between a free zone entity and its mainland-related parties. Where a QFZP has a foreign or domestic permanent establishment, it must also demonstrate that profits attributed to the free zone parent reflect an arm’s length share of overall operating profits, based on the functions performed, assets used, and risks assumed. If the RPT, CP, or Master File/Local File thresholds above are met, a QFZP must complete the same disclosure form and maintain the same documentation as any other taxable person.

The stakes are higher for a QFZP than for a standard taxable person: failing to demonstrate arm’s length pricing, or failing to maintain adequate transfer pricing records, can jeopardise QFZP status itself. Losing that status means the entity’s qualifying income becomes taxable at 9% for the current tax period and the following four tax periods, not just an adjustment to the transaction in question.

Key Sections of the Disclosure Form

Where the thresholds above are met, the disclosure form consists of three main sections:

• Related party transaction schedule
• Connected person schedule
• Adjustments to gains and losses with respect to transactions with related parties

1. Related Party Transaction Schedule

This schedule captures details of transactions with related entities: the names of the parties, their countries of tax residence, the type of transaction, the gross value, the transfer pricing method applied, the arm’s length value, and any tax adjustments. It is structured into three parts.

Gross Income Received from Related Parties: The form requires the full gross value of related party transactions to be reported without netting off discounts or rebates. For instance, if goods worth AED 1,200,000 are sold to a related party with a discount of AED 200,000, the total sale should still be reported as AED 1,200,000, with the discount disclosed separately.

Expenditure Paid to Related Parties: Expenditure transactions, including reimbursements that affect the profit and loss statement or balance sheet, are recorded here.

For both income and expenditure transactions, the following details are required:

• a) Name of the related party
• b) Tax residence
• c) Gross income (AED) or expenditure, as applicable
• d) Arm’s length value (AED)
• e) Transaction type: Goods, Services, Intellectual Property (IP), Interest, Assets, Liabilities, Others
• f) Corporate Tax TRN/TIN (if available)
• g) Transfer pricing method: CUP, RPM, CPM, PSM, or TNMM

The “Others” category covers transactions that do not fit the predefined categories, such as cost-sharing arrangements, guarantees, hedging transactions, or reimbursements. Both the OECD Transfer Pricing Guidelines and Article 34(4) of the Corporate Tax Law permit the use of an “Other Method” where none of the five standard methods is appropriate. The disclosure form itself, however, offers only the five OECD standard methods as selectable options, with no “Other Method” field. Where a taxpayer’s Local File justifies an “Other Method,” selecting the closest applicable standard method on the form (with the full reasoning documented in the Local File) is the practical approach until the FTA clarifies further.

2. Connected Person Schedule

This schedule applies once the AED 500,000 threshold above is crossed for a given connected person (such as a director, officer, or owner). All qualifying payments made to that connected person must be reported, with names, relationships, nature of payments, and amounts. These payments must reflect market value to avoid disallowance for tax purposes, and the schedule should be kept updated as transactions occur.

Non-monetary benefits must also be valued and reported: the market value of the benefit in AED, a description of the benefit, and the valuation method used, entered under “Description of payment or benefit.”

• a) Name of the connected person
• b) Payment or benefit (payment / benefit)
• c) Corporate Tax TRN/TIN (if available)
• d) Description
• e) Value of the payment or benefit provided to the connected person (AED)
• f) Market value of the service or benefit provided by the connected person (AED)

Note that the Connected Persons schedule captures payments and benefits only; unlike the RPT schedule, it does not require disclosure of the transfer pricing method used.

3. Adjustments to Gains and Losses with Respect to Opening Balances

The tax adjustment field reflects the gap between the actual transaction value and the arm’s length value, indicating adjustments needed to align taxable income with market pricing. This is particularly relevant to gains and losses on assets and liabilities acquired from related parties at non-arm’s length prices. Under the Corporate Tax Law’s transitional provisions, opening balances for the first tax period must be restated to the arm’s length standard.

Documents Required

Where the Master File/Local File thresholds are met, the form’s “Additional Attachments” section is used to upload supporting documents:

1. Financial statements
2. Local File
3. Master File
4. Confirmation of ownership and right to utilise Qualifying Intellectual Property (patents, copyrighted software, or similar)
5. Record of qualifying expenditure and total expenses incurred
6. Record of total income from qualifying expenditure and qualifying IP
7. Documentation verifying the market value of qualifying immovable property at the start of the first tax period
8. Documentation verifying the market value of financial assets/liabilities at the start of the first tax period
9. Tax residency certificate from the relevant foreign jurisdiction

Even outside the formal filing, the Master File and Local File must be prepared contemporaneously, meaning they should be ready by the time the tax return or TP Disclosure Form is filed, and made available to the FTA within 30 days of a request.

Penalties for Non-Compliance

There is no TP-specific penalty regime as such. Instead, penalties apply under the general Corporate Tax administrative penalty framework (Cabinet Decision No. 75 of 2023), covering three distinct violations that can each arise from a TP filing: failure to file the Corporate Tax Return (which carries the TP Disclosure Form) on time, submitting incorrect or incomplete disclosures, and failing to maintain the required TP documentation when requested:

• Late filing of the Corporate Tax Return (which carries the TP Disclosure Form): AED 500 per month for the first 12 months, rising to AED 1,000 per month thereafter.
• Submitting incorrect information in a tax return or form, including the TP Disclosure Form: AED 500 for a first-time violation, AED 1,000 for repeat violations.
• Failure to maintain required records (including TP documentation) when requested: penalties starting at AED 10,000 per violation, rising to AED 20,000 for repeat violations within 24 months.

Where the FTA determines a controlled transaction was not priced at arm’s length, it can also adjust taxable income directly. This can trigger additional tax, a monthly late-payment penalty, and interest on the shortfall, independent of the filing penalties above.

Key Takeaways

1. The TP Disclosure Form is not required in full for every related party or connected person transaction. Materiality thresholds apply (AED 40 million aggregate for the RPT schedule, AED 4 million per category, AED 500,000 per connected person for the CP schedule, and AED 200 million / AED 3.15 billion for Master File and Local File requirements). Businesses below these thresholds must still price all related party and connected person transactions at arm’s length and be prepared to substantiate this if asked, even without a formal disclosure or documentation obligation.
2. There is no TP-specific penalty separate from the Corporate Tax Law’s general administrative penalty framework. Late filing follows the standard escalating monthly penalty; incorrect disclosure carries its own fixed penalty; failure to produce records on request carries a separate, higher penalty.
3. The disclosure form’s five transfer pricing method options do not include an “Other Method,” even though Article 34(4) permits its use. Where a secondary or bespoke method is more appropriate, taxpayers should select the closest standard method on the form and document the reasoning in the Local File.
4. Per the FTA’s Transfer Pricing Guide (paragraph 7.8.2), receivable balances should be realised within the arm’s length credit period. Where a balance exceeds arm’s length credit terms, tax authorities may treat the outstanding receivable as a separate transaction; taxpayers should consider applying the same transfer pricing method used for the underlying transaction to this receivable.
5. Transactions in foreign currencies must be converted to AED using the exchange rate applicable on the transaction date, or a consistently applied average rate for the period.
6. Entities electing Small Business Relief (available where revenue is AED 3 million or less in the current and all previous tax periods, up to tax periods ending 31 December 2026) are not required to maintain formal TP documentation, but they must still price related party transactions at arm’s length, and may still need to file the disclosure form if the relevant thresholds are otherwise met.
7. Transactions between entities within the same Tax Group are outside the scope of transfer pricing rules and the disclosure form, since intra-group transactions are eliminated on consolidation.
8. The Corporate Tax Law exempts qualifying tax-neutral transactions from TP documentation requirements, but the disclosure form itself does not carry a parallel exemption, so these transactions may still need to be reported where thresholds are met.
9. Both the Corporate Tax Law and the TP Guide permit using a combination of transfer pricing methods to support the arm’s length nature of a transaction, but the disclosure form only allows selection of one primary method per transaction. Taxpayers should select the most representative method for the form and retain the full methodology in the Local File.
10. For Suo-moto (self-initiated) adjustments where a transaction falls outside the arm’s length range, Article 34(10) permits a taxable person (not just the Authority) to adjust its own Taxable Income to meet the arm’s length standard. Selecting the median of the comparable dataset as the adjustment point is generally the more conservative and defensible approach, compared to using either end of the range.
11. Qualifying Free Zone Persons carry extra exposure on transfer pricing: non-compliance can result in the loss of QFZP status and the 0% rate for the current tax period plus the following four tax periods, on top of any standard TP penalties or adjustments.

Frequently Asked Questions

Is there a minimum threshold for UAE transfer pricing rules?

Yes, for disclosure purposes. The arm’s length principle itself has no minimum, but you only need to complete the RPT schedule once aggregate related party transactions exceed AED 40 million, the CP schedule once payments to a connected person exceed AED 500,000, and the Master File/Local File once revenue thresholds of AED 200 million (entity) or AED 3.15 billion (group) are met.

What happens if my business is below all the disclosure thresholds?

You are not required to complete the detailed schedules or maintain a Master File/Local File, but you must still price related party and connected person transactions at arm’s length and be able to justify this if the FTA asks.

Do free zone companies need to file the TP Disclosure Form?

Free zone entities that transact with related parties, including their own mainland-related entities, are subject to the same transfer pricing rules and thresholds as any other UAE taxable person.

What is the deadline for filing the TP Disclosure Form?

It is filed together with the Corporate Tax Return, due 9 months after the end of the relevant tax period. A 31 December 2025 year-end, for example, falls due on 30 September 2026.

What is the penalty for filing the TP Disclosure Form late?

Late filing follows the standard Corporate Tax Return penalty: AED 500 per month for the first 12 months, then AED 1,000 per month thereafter. Incorrect information carries a separate penalty of AED 500 for a first violation and AED 1,000 for repeat violations.

Does transfer pricing affect Qualifying Free Zone Person (QFZP) status?

Yes, directly. Maintaining the 0% rate on qualifying income requires a QFZP to price related party transactions at arm’s length and keep adequate transfer pricing records. Non-compliance can result in losing QFZP status, which makes qualifying income taxable at 9% for the current tax period and the following four tax periods.

Glossary

#	Term/Acronym	Full Form
1	AED	United Arab Emirates Dirham
2	CP	Connected Person
3	CPM	Cost-Plus Method
4	CT	Corporate Tax
5	CUP	Comparable Uncontrolled Price Method
6	EmaraTax	The FTA’s online platform for registration, return filing, tax payment, and refunds in the UAE
7	FTA	Federal Tax Authority
8	IP	Intellectual Property
9	MNE	Multinational Enterprise
10	OECD	Organisation for Economic Co-operation and Development
11	PSM	Profit Split Method
12	RPM	Resale Price Method
13	RPT	Related Party Transaction
14	TNMM	Transactional Net Margin Method
15	TP	Transfer Pricing
16	TPDF	Transfer Pricing Disclosure Form
17	UAE	United Arab Emirates

Please verify current thresholds and deadlines with BCL before relying on them for a specific filing.

Not sure whether your business crosses these thresholds, or need help pulling your Local File together before the deadline? BCL’s Transfer Pricing team can run a quick threshold check and take the disclosure and documentation off your plate. Reach us at info@bcl.ae or +971 55 942 9740.

Also Read

• Transfer Pricing Updates in UAE
• Corporate Tax Guide UAE
• Economic Substance Regulation in UAE
• Penalties Under UAE Corporate Tax Law
• Ultimate Beneficial Ownership UAE Guide