{"id":6219,"date":"2026-02-25T12:04:17","date_gmt":"2026-02-25T12:04:17","guid":{"rendered":"https:\/\/well-tax.com\/?p=6219"},"modified":"2026-02-25T12:04:18","modified_gmt":"2026-02-25T12:04:18","slug":"7-%d0%bf%d1%80%d0%b0%d0%ba%d1%82%d0%b8%d1%87%d0%b5%d1%81%d0%ba%d0%b8%d1%85-%d1%81%d0%be%d0%b2%d0%b5%d1%82%d0%be%d0%b2-%d0%bf%d0%be-%d0%b7%d0%b0%d0%bf%d0%be%d0%bb%d0%bd%d0%b5%d0%bd%d0%b8%d1%8e-%d1%84","status":"publish","type":"post","link":"https:\/\/well-tax.com\/ru\/7-practical-tips-for-filing-the-transfer-pricing-disclosure-form-uae\/","title":{"rendered":"7 \u043f\u0440\u0430\u043a\u0442\u0438\u0447\u0435\u0441\u043a\u0438\u0445 \u0441\u043e\u0432\u0435\u0442\u043e\u0432 \u043f\u043e \u0437\u0430\u043f\u043e\u043b\u043d\u0435\u043d\u0438\u044e \u0444\u043e\u0440\u043c\u044b \u0440\u0430\u0441\u043a\u0440\u044b\u0442\u0438\u044f \u0438\u043d\u0444\u043e\u0440\u043c\u0430\u0446\u0438\u0438 \u043e \u0442\u0440\u0430\u043d\u0441\u0444\u0435\u0440\u0442\u043d\u043e\u043c \u0446\u0435\u043d\u043e\u043e\u0431\u0440\u0430\u0437\u043e\u0432\u0430\u043d\u0438\u0438 \u0432 \u041e\u0410\u042d"},"content":{"rendered":"\n
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The UAE\u2019s corporate tax landscape has changed significantly with the introduction of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses. As part of this new regime, businesses are now required to comply with detailed transfer pricing rules. A key component of these rules is the Transfer Pricing Disclosure Form UAE, which must be filed as part of the annual Corporate Tax (CT) return.<\/p>\n\n\n\n

This form is designed to ensure that transactions with related parties and connected persons adhere to the Arm\u2019s Length Principle. Failing to comply can lead to administrative penalties or adjustments by the Federal Tax Authority (FTA). In this guide, we explain what businesses need to know, highlight the key thresholds, and provide practical steps to complete the disclosure efficiently while remaining compliant.<\/p>\n\n\n\n

1. Understand the Role of the Transfer Pricing Disclosure Form UAE<\/h2>\n\n\n\n

The Transfer Pricing Disclosure Form UAE is not a separate filing. It is integrated into your Corporate Tax return, which is submitted via the EmaraTax portal. This means you cannot submit it independently; it must be completed alongside your annual CT filing.<\/p>\n\n\n\n

Businesses must file the disclosure within nine months after the end of their relevant tax period<\/strong>. For instance, companies with a financial year ending December 31, 2025, must submit their first form by September 30, 2026. Missing this deadline can trigger administrative penalties in addition to late filing fines, so careful planning is essential.<\/p>\n\n\n\n

Completing the disclosure on time also demonstrates good governance and helps minimize audit risks. The FTA uses the form to identify related-party transactions and ensure that intercompany pricing reflects market conditions.<\/p>\n\n\n\n

2. Know the Relevant Thresholds<\/h2>\n\n\n\n

Not all businesses are required to complete every section of the Transfer Pricing Disclosure Form UAE. The FTA has established materiality thresholds to focus reporting on transactions of significant value:<\/p>\n\n\n\n

Related Party Transactions<\/h3>\n\n\n\n

This section must be completed if the aggregate value of transactions with related parties exceeds AED 40 million in a tax period.<\/p>\n\n\n\n

Category-Specific Reporting<\/h3>\n\n\n\n

Once the AED 40 million threshold is exceeded, any individual transaction category (such as goods, services, or interest) exceeding AED 4 million must be detailed separately.<\/p>\n\n\n\n

For example, if your total related-party transactions exceed AED 40 million in a tax period, any single transaction over AED 4 million must be reported separately. So, if your company buys goods worth AED 5 million from a related entity, you need to disclose this transaction in detail, even if your total related-party transactions are only slightly above the AED 40 million threshold.<\/p>\n\n\n\n

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3. Disclose Payments to Connected Persons<\/h2>\n\n\n\n

The Transfer Pricing Disclosure Form UAE has a dedicated section for payments to \u201cConnected Persons,\u201d including directors, owners, and their relatives. If payments or benefits to a single connected person exceed AED 500,000 in a tax period, they must be disclosed.<\/p>\n\n\n\n

It is important to note that such payments are only deductible if they match the market value of the services provided. For example, if a director receives a salary significantly above market rates, the excess amount must be reported as a non-deductible adjustment. Failure to comply with these rules could result in disallowed deductions and potential penalties.<\/p>\n\n\n\n

4. Apply the Arm\u2019s Length Principle<\/h2>\n\n\n\n

At the heart of the Transfer Pricing Disclosure Form UAE is the Arm\u2019s Length Principle. Transactions between related parties must reflect what independent parties would agree under comparable circumstances.<\/p>\n\n\n\n

The form requires you to specify the transfer pricing method used, such as the Transactional Net Margin Method (TNMM) or the Comparable Uncontrolled Price (CUP) method. Choosing the right method is crucial, as the FTA will expect a clear rationale for why it is the most appropriate for your business model and transaction type. For businesses with international operations or cross-border related-party transactions, WellTax provides guidance on UAE and UK transfer pricing rules and global considerations<\/strong><\/a>.<\/p>\n\n\n\n

Businesses often make the mistake of selecting a method without proper benchmarking. Ensuring your method is supported by contemporaneous data is key to avoiding adjustments during an FTA review.<\/p>\n\n\n\n

5. Prepare Documentation in Advance<\/h2>\n\n\n\n

One common mistake is waiting until an audit to start your transfer pricing documentation, and it creates unnecessary pressure and increase the risk of errors. Businesses need \u201ccontemporaneous\u201d evidence ready at the time of filing. Best practices include:<\/p>\n\n\n\n

Benchmarking Studies<\/h3>\n\n\n\n

Use reliable market data to support your pricing. This demonstrates that your intercompany transactions are at arm\u2019s length. WellTax can provide practical support for transfer pricing benchmarking and documentation<\/strong>, helping businesses feel confident that their disclosure meets regulatory requirements. Learn more about our Transfer Pricing Benchmarking & Advisory<\/strong><\/a>.<\/p>\n\n\n\n

Local and Master Files<\/h3>\n\n\n\n

These are mandatory if your revenue exceeds AED 200 million or you are part of a large multinational enterprise (MNE). The Local File provides detailed documentation of intercompany transactions, while the Master File provides an overview of the multinational group.<\/p>\n\n\n\n

Professional Support<\/h3>\n\n\n\n

Engaging a tax advisor for benchmarking analysis and documentation review can ensure compliance and reduce audit risk. WellTax can provide practical support at key stages, helping businesses feel confident that their disclosure and documentation meet regulatory requirements.<\/p>\n\n\n\n

By having documentation ready when submitting the disclosure, businesses can avoid penalties and streamline any future FTA reviews.<\/p>\n\n\n\t\t

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