Most UAE business owners preparing their first corporate tax return think transfer pricing is a problem for multinationals. Then they add up what they paid a sister company, a shareholder, and a director over the year, and the number clears AED 40 million. At that point a Transfer Pricing Disclosure Form becomes part of your return, whether you trade across borders or entirely within Dubai.
TL;DR: If your UAE company's related-party transactions exceed AED 40 million in a tax period, you file a Transfer Pricing Disclosure Form with your corporate tax return through EmaraTax. Payments to any one connected person above AED 500,000 need disclosing too. Everything runs on the arm's length principle, and an incomplete return carries penalties.
What Is the Related Party Disclosure Form?
It is a schedule you submit alongside your corporate tax return that summarises transactions with related parties and connected persons for the tax period. It is not a separate filing with its own deadline. It sits inside the return you file on EmaraTax within nine months of your tax period end.
The form asks for the nature of each relationship, the type of transaction, the total value per category, and the jurisdiction of the related party. It exists so the Federal Tax Authority (FTA) can see, at a glance, which businesses are moving money between connected entities and whether those transactions were priced on arm's length terms under Article 34 of the Corporate Tax Law.
Who Has to File It in the UAE?
You complete the related-party schedule once your aggregate related-party transactions exceed AED 40 million in the tax period. Below that, no schedule is required. Above it, you then disclose each transaction category whose value exceeds AED 4 million (PwC, 2026).
A second test runs in parallel for connected persons. Where the aggregate payment or benefit to any single connected person, together with their related parties, exceeds AED 500,000, that connected-person schedule is triggered (PwC, 2026). In our experience the connected-person test is the one owner-managed companies miss, because a director's salary that looks commercial can still push a shareholder's total benefit over the line once dividends, loans, and expenses are added together.
What Counts as a Related Party or Connected Person?
A related party is broadly anyone you are tied to by ownership, control, or family. Article 35 of the Corporate Tax Law captures two natural persons related up to the fourth degree of kinship, any party holding 50% or more ownership or control, a person and their permanent establishment, and partners in the same unincorporated partnership.
A connected person is narrower and points at the people behind the business. Under Article 36, that means an owner of the taxable person, a director or officer, and the related parties of either. So a payment from your company to your own holding entity is a related-party transaction, while your salary and dividends as the owner are connected-person transactions. Both can appear on the same return.
Which Transactions Go on the Form
Sales are only one part of it. Every value transfer between connected entities counts, and the categories include goods, services, intellectual property and royalties, interest and financing arrangements, and asset transfers. Balance-sheet items count too, which is where the AED 40 million threshold catches people out.
What we see most often is a company that counts only its intercompany invoices and forgets a AED 30 million loan from its parent. Add the loan principal to a few million in management fees and the aggregate clears AED 40 million on its own. The FTA looks at the full picture across the profit and loss account and the balance sheet, so intercompany loans, guarantees, and asset movements all belong in the calculation.
The Form Is Not the Same as Master and Local File
Filing the disclosure form does not mean you also need a Master File and Local File. Those are separate, heavier documentation obligations that apply only when your revenue reaches AED 200 million, or when you are part of a multinational group with consolidated revenue of AED 3.15 billion or more (Ministerial Decision No. 97 of 2023, 2023).
Most UAE SMEs sit above the AED 40 million disclosure threshold but well below the AED 200 million documentation threshold. If that is you, the disclosure form is your obligation, and the detailed transfer pricing files are not. Where you do cross into Master and Local File territory, those documents must be ready to hand to the FTA within 30 days of a request (DLA Piper, 2023). This is one area where being a UAE permanent establishment of a foreign firm changes the analysis, so check your group structure before you decide you are out of scope.
What Happens If You Get It Wrong?
The disclosure form is part of your return, so an incomplete or inaccurate one is an incorrect return. That carries an administrative penalty, and more importantly it invites the FTA to look harder at whether your related-party pricing was actually arm's length. If the FTA decides it was not, it can adjust your taxable income upward and apply penalties on the additional tax.
One trap catches businesses trying to reduce taxable income through a downward transfer pricing adjustment: that adjustment needs prior FTA approval. Claim it on your return without approval and you have filed an error. One question clients always ask is whether a purely domestic group is exempt because nothing crosses a border. It is not. The rules apply to related-party transactions inside the UAE just as they do to cross-border ones, so a Dubai holding company charging its Dubai subsidiary a management fee is squarely in scope. Getting the first corporate tax return right matters, because the FTA can revisit these positions for years afterward.
Frequently Asked Questions
When is the Transfer Pricing Disclosure Form due?
It is filed with your corporate tax return, which is due within nine months of the end of your tax period. For a company with a 31 December 2025 year-end, that means the return and the disclosure form are both due by 30 September 2026. There is no separate submission date for the form.
Do I need the form if all my related-party transactions are inside the UAE?
Yes, if they exceed the thresholds. The AED 40 million aggregate test and the AED 500,000 connected-person test apply to domestic transactions as well as cross-border ones. A management charge or intercompany loan between two UAE entities counts the same as one paid overseas.
Does a AED 30 million intercompany loan count toward the AED 40 million threshold?
Yes. Balance-sheet items such as intercompany loans and guarantees count toward the aggregate figure, alongside profit-and-loss transactions. This is the most common reason companies that thought they were below the threshold turn out to be above it once the full balance sheet is added in.
Is the disclosure form the same as a full transfer pricing study?
No. The disclosure form is a summary schedule inside the return. A full Master File and Local File study is only required at AED 200 million taxpayer revenue, or AED 3.15 billion consolidated group revenue. Many businesses need the form but not the study.
What if my related-party transactions are below AED 40 million?
You do not file the related-party schedule. You still have to apply the arm's length principle to any related-party dealings, and the connected-person schedule can still apply if payments to a single connected person exceed AED 500,000. Keep the supporting evidence either way in case the FTA asks.
Not sure whether your intercompany balances push you over the AED 40 million line? Get in touch - we work with UAE groups and owner-managed companies on corporate tax filings and can check your related-party position before your return is due.