United Arab Emirates Transfer Pricing Documentation Requirements
The United Arab Emirates introduced transfer pricing documentation under its corporate tax regime, requiring a Master File and Local File where the taxpayer is part of a large multinational group or meets the standalone revenue test. A transfer pricing disclosure form is filed with the corporate tax return, and documentation is produced within 30 days of a request.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Constituent entity of an MNE group with consolidated revenue > AED 3.15bn, or meeting the standalone revenue test | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | EN | Yes (under the UAE Tax Procedures Law) |
Local File Required | Same conditions as the Master File | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | EN | Yes (under the UAE Tax Procedures Law) |
Disclosure form Annual filing | Taxpayers with related-party transactions | With the corporate tax return | Submission deadline The documentation must be filed with the tax authority by the date shown. | EN | Yes |
CbC report Required | Group revenue ≥ AED 3,150m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
Under Ministerial Decision No. 97 of 2023, a taxable person must maintain a Master File and a Local File where it is a constituent entity, including a mainland or free-zone subsidiary, branch, or permanent establishment, of a multinational group with annual consolidated group revenue exceeding AED 3.15 billion, or where it meets the standalone revenue test set in the decision. The documentation is produced within 30 days of a request, and a transfer pricing disclosure form is filed with the corporate tax return.
Distinctive features of the UAE regime
The defining feature of the UAE regime is its recency and its integration into a newly introduced corporate tax. The documentation requirement arrived alongside the federal corporate tax, so it represents a first-generation regime rather than an evolution of long-standing rules, and the inclusion of free-zone entities within the scope of the obligation is a notable feature given the role of free zones in the economy. There are no documentation-specific penalties; non-compliance is sanctioned under the Tax Procedures Law. Aggregation under the transactional net margin method is possible where transactions are sufficiently interlinked.
Benchmarking and comparables
Foreign comparables may be used. Multi-year analysis is preferred. Comparable searches should be fully updated every three years, with an annual financial update of the comparables in the interim years as a minimum, and a full re-selection of comparables undertaken in any year in which the circumstances of the controlled transaction or the related parties change. There is no transfer-pricing-specific limitation period: the general rule under the Tax Procedures Law of five years after the end of the relevant tax period applies.
Frequently asked questions
Are UAE free-zone entities within the transfer pricing documentation rules?
Yes. A constituent entity that is a free-zone subsidiary, branch, or permanent establishment is within the Master File and Local File requirement where the group or standalone revenue conditions are met.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.