UAE Corporate Tax follows the OECD arm’s length principle: transactions between related parties and with connected persons — shareholders, directors, sister companies, a UK or Portuguese group company — must be priced as if they were between independent parties. Management fees, loans, recharges and services are the usual suspects.
What the UAE expects
- Arm’s length pricing for every transaction with related parties and payments to connected persons.
- A transfer pricing disclosure form filed with the Corporate Tax return when related-party transactions exceed the thresholds.
- A master file and local file for businesses with UAE revenue of AED 200 million or more, or part of a multinational group with consolidated revenue of AED 3.15 billion or more.
- Documents provided to the FTA within 30 days of a request.
International groups
Many SJPR clients have companies in the UAE, the UK and Portugal. We price and document the transactions between them once, consistently in each country — so the same fee is not challenged twice. That is the advantage of one team across three jurisdictions.
Frequently asked questions
Does transfer pricing apply to small companies?
The arm’s length principle applies to everyone. The full master and local file is only required above the thresholds, but every company should be able to justify its related-party prices.
Who is a connected person?
Broadly, an owner, director or officer of the business, or someone related to them. Payments to connected persons are deductible only to the extent they are at market value and for the business.
Do I need intercompany agreements?
Yes — written agreements that match what really happens are the first thing the FTA asks for. We draft them with the pricing analysis.
This guide reflects UAE law and FTA guidance as at October 2026. It is general information, not advice for your specific situation — rules and thresholds change, so speak to an SJPR advisor before acting.
