Transfer Pricing Documentation for UAE Businesses (2026)

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.

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.

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.

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.

Finanshels' tax consultation and corporate tax filing services cover transfer pricing mapping, Disclosure Form preparation and Local File readiness for UAE groups.