UAE transfer pricing documentation comes in four forms — the Disclosure Form, the Master File, the Local File, and the Country-by-Country Report — and which ones apply to you is decided by revenue thresholds set at AED 40,000,000 for related-party disclosure and AED 200,000,000 for the Local File. Miss the threshold and file nothing, and the FTA can still demand the documents within 30 days of a request; fail to produce them and penalties start at AED 20,000.
TL;DR
- Disclosure Form: required when related-party transactions exceed AED 40,000,000.
- Local File: required when UAE revenue is AED 200,000,000+ or the entity is part of an MNE group.
- Master File: required for MNE groups with consolidated revenue of AED 3,150,000,000+.
- Country-by-Country Report: filed by the UAE parent of an MNE group with global revenue of AED 3,150,000,000+.
- The FTA can demand any of these within 30 days of a written request.
What counts as transfer pricing documentation in the UAE
Under Federal Decree-Law No. 47 of 2022 (Art. 55) and its Executive Regulation, four separate documents exist — they have different triggers, so a business can owe one and not the others.
Which document applies to you? (thresholds per FTA guidance and Federal Decree-Law No. 47 of 2022, checked September 2026)
Disclosure Form
- Trigger: Aggregate related-party transactions exceed AED 40,000,000; individual category exceeds AED 4,000,000
- Filed with: With the annual CT return
- Deadline: Same as CT return (9 months after period end)
Local File
- Trigger: UAE revenue of AED 200,000,000+ in a tax period, or entity is part of an MNE group
- Filed with: On request
- Deadline: Within 30 days of FTA request
Master File
- Trigger: Entity is part of an MNE group (consolidated revenue AED 3,150,000,000+); UAE-only groups are exempt
- Filed with: On request
- Deadline: Within 30 days of FTA request
Country-by-Country Report
- Trigger: UAE parent of an MNE group with consolidated group revenue of AED 3,150,000,000+
- Filed with: Filed with the CT return of the ultimate parent
- Deadline: Per CbC filing deadline
How to prepare transfer pricing documentation
Step 1 — Map your related-party transactions
List every transaction with a related party: goods, services, intellectual property, interest, assets, liabilities, and "other". Include financing arrangements — a loan between related parties counts toward the AED 40,000,000 threshold even though principal and interest affect taxable income differently.
Step 2 — Aggregate and test the AED 40,000,000 threshold
Sum the total value of all related-party transactions recorded in your financial statements, or at market value where the accounting does not reflect them. If the aggregate exceeds AED 40,000,000, you must complete the Disclosure Form. Within that, any single category above AED 4,000,000 must be broken out separately.
Worked example: a mainland trading company with two related parties
- Purchases from a related trading company: AED 25,000,000 (goods category)
- Management fees paid to a related holding company: AED 6,000,000 (services category)
- Loan from a related party, drawn and repaid in the same period: AED 12,000,000 (financing/asset-liability category)
- Aggregate related-party transactions: AED 43,000,000 — above AED 40,000,000, so a Disclosure Form is required
- All three categories individually exceed AED 4,000,000, so all three are disclosed separately
Step 3 — Check the Local File trigger
The Local File is required when a taxable person's UAE revenue reaches AED 200,000,000 in a tax period, or when the entity is part of a multinational group. A UAE-headquartered group with no entities abroad is exempt from the Master File but still owes the Local File if revenue crosses AED 200,000,000.
Step 4 — Prepare the Local File content
Per the FTA Transfer Pricing Guide, a Local File documents: the organisational structure, the nature of related-party transactions, the amounts and currencies, the transfer pricing method selected, the comparables analysis, and the financial information supporting the arm's length conclusion.
Step 5 — File the Disclosure Form with your CT return
The Disclosure Form is submitted alongside the annual corporate tax return — due within nine months of the end of the tax period. The form asks for transaction categories, amounts, and the arm's length value where different from the recorded value.
Step 6 — Hold everything ready for a 30-day request
The FTA can request Master File, Local File or supporting documentation at any time, and you must produce it within 30 days of the request (or a later date the FTA specifies). Keeping the documents current — not scrambling at request time — is the difference between a routine compliance check and an assessment with penalties.
The penalty exposure
Failure to keep the required transfer pricing documentation
- Penalty: AED 20,000 per violation
- Source: Cabinet Decision No. 75 of 2023 (amending Cabinet Decision 40 of 2017)
Failure to submit the Disclosure Form with the CT return
- Penalty: Treated as an incomplete return; late or incorrect return penalties apply
- Source: Federal Decree-Law No. 47 of 2022, Art. 55
Related-party vs connected-person thresholds
Connected persons (individuals who control the business, related parties of those individuals, and their relatives) have a much lower disclosure threshold: AED 500,000 in aggregate payments or benefits to connected persons triggers disclosure, not AED 40,000,000. A sole shareholder drawing management fees above this threshold should expect to disclose it.
Threshold summary — quick reference
Related-party transactions, aggregate
- Threshold: AED 40,000,000
- Consequence when exceeded: Disclosure Form required with CT return
Related-party transactions, per category
- Threshold: AED 4,000,000
- Consequence when exceeded: Category broken out on the Disclosure Form
Connected persons, aggregate
- Threshold: AED 500,000
- Consequence when exceeded: Disclosed on the Disclosure Form
UAE revenue (any taxpayer)
- Threshold: AED 200,000,000
- Consequence when exceeded: Local File required
MNE group consolidated revenue
- Threshold: AED 3,150,000,000
- Consequence when exceeded: Master File and Country-by-Country Report obligations
FAQs
What is the AED 40,000,000 threshold for transfer pricing documentation in the UAE?
It is the aggregate value of related-party transactions that triggers the Disclosure Form with your annual corporate tax return. Any single category of transactions above AED 4,000,000 must also be disclosed separately once the aggregate threshold is crossed.
When does a UAE company need a Local File?
When UAE revenue reaches AED 200,000,000 in a tax period, or when the company is part of a multinational group. The FTA's Transfer Pricing Guide sets out the required content: organisational structure, transaction nature, transfer pricing method, comparables and financial analysis.
Is a Master File required for a UAE-only group?
No — a UAE-headquartered group that does not operate outside the UAE is exempt from the Master File, but the Local File obligation still applies if revenue exceeds AED 200,000,000.
How quickly must I produce transfer pricing documents if the FTA asks?
Within 30 days of the FTA's request, or a later date the FTA specifies. The documents must be prepared and maintained each tax period, not assembled after the fact.
Last reviewed: September 2026 by Gautam Sanoj, Associate Manager – Tax Advisory, Finanshels. Rules per Federal Decree-Law No. 47 of 2022, Art. 55, and current FTA guidance; verify thresholds against tax.gov.ae before acting.
Sources and further reading
- Federal Decree-Law No. 47 of 2022 on Corporate Taxation, Art. 55 (Transfer Pricing Documentation).
- FTA Transfer Pricing Guide (EN)
- Cabinet Decision No. 57 of 2024 — CT Executive Regulation
- Cabinet Decision No. 40 of 2017 as amended — administrative penalties
- Grant Thornton — UAE transfer pricing thresholds summary
Finanshels' tax consultation and corporate tax filing services cover transfer pricing mapping, Disclosure Form preparation and Local File readiness for UAE groups.
