02 / FROM THE SOURCESWhat the official documents say.
UAE Corporate Tax requires that dealings between related parties — companies under common ownership, or a business and its owners — are priced as if they were between independent parties. This is the arm's length principle.
If related-party transactions are mispriced to shift profit out of the UAE, the Federal Tax Authority can adjust your taxable income upward and tax the difference.
Larger groups must keep formal documentation: a Master File describing the global group and a Local File covering UAE transactions, both produced to the FTA on request.
A group generally needs a Master File once consolidated revenue reaches about AED 3.15 billion, and a Local File once related-party transactions in a category exceed roughly AED 40 million.
Every business with related-party dealings must also complete a transfer pricing disclosure form alongside its annual Corporate Tax return, regardless of size.
03 / THE KEY FACTSThe figures, with their sources.
| Fact | Value | Source |
|---|---|---|
| Arm's length principle applies to | All related-party transactions | FTA — Transfer Pricing Guide CTGTP1 |
| Master file threshold (group revenue) | AED 3,150,000,000+ | FTA — Transfer Pricing Guide |
| Local file threshold (related-party transactions) | AED 40,000,000+ per category | FTA — Transfer Pricing Guide |
| Disclosure form required with tax return | Yes — if related-party transactions exist | FTA — Transfer Pricing Guide |
04 / SOURCES & DOWNLOADSKnow what this guide rests on.
Legal basis: 2 primary source documents. Laws change; verify with the issuing authority before acting.