Transfer Pricing in the UAE. Threshold Values

20 / 03 / 2025

TRANSFER PRICING IN THE UAE. THRESHOLD VALUES

In the UAE, transfer pricing rules apply and must be observed by all companies, including those registered in Free Zones. To comply with these requirements, taxpayers are required to submit the Transfer Pricing Disclosure Form together with the corporate tax return if they have controlled transactions exceeding the threshold value.

Transactions with Related Parties

If, during the current tax period, the company carried out transactions with related parties and the aggregate amount of all transactions with all related parties reflected in the financial statements at market value exceeded AED 40 million, a special section to the return must be completed — the Notification Form (Related Party Transaction Schedule).

At the same time, the taxpayer must disclose information by income/expense category for each related party if the aggregate amount under such transaction exceeds AED 4 million. Dividends are not subject to this requirement.

Certain taxpayers, upon exceeding the established financial thresholds, must submit a Master File and Local File. This requirement applies to the following companies:

• Companies that are part of a multinational group (MNG) with annual consolidated revenue of from AED 3.15 billion; and/or

• Companies with revenue of more than AED 200 million in the relevant tax period.

In addition, a company that is a member of an MNG may be required to submit a Country-by-Country report if that company is the parent company or the company responsible for preparing such a report.

Transactions with Connected Persons

If, during the current tax period, the company carried out transactions with connected persons with an aggregate transaction value with at least one connected person exceeding AED 500 thousand, a special section to the return must be completed — the Notification Form (Connected Persons Schedule).

In this case, information is disclosed not for all transactions with connected persons, but only where the aggregate income/expenses exceed AED 500 thousand with one connected person (together with their related parties).

What do we offer?

ALPINE GROUP specialists will provide qualified support on the following matters:

Analysis of the current business structure to identify transfer pricing risks;
Analysis of current and projected international related-party transactions for compliance with transfer pricing rules and recommendations for bringing transaction terms into line with UAE legislative requirements;
Preparation of transfer pricing reporting;
Advisory on specific transfer pricing matters.

For any questions you may have, please contact us by email or phone.

Dubai:
info@aigroup.ae
+971 4 575 63 24

Moscow:
info@alpinetax.ru
+7 495 025 02 66