Transfer Pricing
The UAE Transfer Pricing Disclosure Form
No separate form exists to download. The UAE transfer pricing disclosure is two schedules inside the corporate tax return — the triggers and every field.
uae transfer pricing disclosure form
The UAE transfer pricing disclosure is not a standalone document you download and post. It is two schedules inside the corporate tax return in EmaraTax: the Related Party Transaction Schedule, which opens once related-party transactions exceed AED 40 million in aggregate, and the Connected Persons Schedule, which opens above AED 500,000. Both are filed with the return, nine months after the tax period ends.
Basis: Federal Tax Authority
- Related Party Transaction Schedule trigger
- Aggregate related-party transactions above AED 40 million
- Per-category reporting trigger
- Above AED 4 million per transaction category
- Connected Persons Schedule trigger
- Above AED 500,000 per connected person
- Filing date
- With the tax return, 9 months after the tax period ends
- Standalone downloadable form
- None published
CTGTXR1 section 16.1
CTGTXR1 section 16.1
CTGTXR1 section 16.2
Article 53(1), Federal Decree-Law No. 47 of 2022
Checked on the FTA guides pages, 21 August 2026
#Where the disclosure actually lives: inside the corporate tax return
People search for a transfer pricing disclosure form because the FTA's own guidance calls it one. The Transfer Pricing Guide (CTGTP1) devotes section 6.5 to a "general Transfer Pricing disclosure form" that taxable persons above a materiality threshold must "prepare and submit ... alongside their Tax Return", under Article 55(1) of the Corporate Tax Law.
What exists in practice is narrower. The Tax Returns Guide (CTGTXR1) sets out the actual return, and the disclosure is delivered through two of the return's schedules in Part I: schedule 6, the Related Party Transaction Schedule, and schedule 7, the Connected Persons Schedule. There is no separate submission, deadline or reference number.
The return is filed online through EmaraTax, and CTGTXR1 states that a taxable person only sees the fields and schedules that may be applicable to them. A schedule that never appears has not been skipped; it was switched off by an answer given earlier in the return.
#There is no PDF to download, and the promised sample was never published
The most common search behind this page is someone hunting for a transfer pricing disclosure form as a PDF or a sample they can inspect before filing. We could not find one, and we are not going to link to a third-party reconstruction of it.
CTGTP1, section 6.5, says in terms: "A sample of the Transfer Pricing disclosure form to be completed annually by Taxable Persons will be available in due course on the FTA's website." That guide is dated 23 October 2023 and its FTA landing page shows a last update of 6 November 2023. Checked on 21 August 2026, that landing page carries the guide PDF and nothing else — no sample form, no separate download.
The practical substitute is better than a sample anyway: CTGTXR1 documents every field of both schedules by number, and the tables below reproduce that field list. Reading it is how you find out what you will be asked before you open the return.
#The two thresholds that switch the schedules on
There is no single transfer pricing disclosure threshold. There are three numbers, two controlling whether a schedule opens at all and one controlling what goes inside it. All three come from CTGTXR1, sections 9.3 and 16, and they are thresholds for disclosure only — they have nothing to do with the AED 200 million and AED 3.15 billion documentation thresholds in Ministerial Decision No. 97 of 2023.
| Test | Threshold | Consequence |
|---|---|---|
| Aggregate value of all transactions with all related parties, recorded in the financial statements or at market value | Exceeds AED 40 million | You are directed to complete the Related Party Transaction Schedule |
| Aggregate transaction value per category, with all related parties | Exceeds AED 4 million | That category must be disclosed inside the schedule, once the AED 40 million gate is passed |
| Aggregate value of transactions with connected persons, including their related parties | Exceeds AED 500,000 | The Connected Persons Schedule must be completed, for each connected person above that amount |
Dividends are excluded from the AED 40 million test
CTGTXR1 states that dividends declared between related parties do not need to be disclosed in the schedule and should not be taken into account in determining the AED 40 million or AED 4 million thresholds.
That exclusion decides the answer for a large number of UAE holding structures. A group whose intra-group flows are mostly dividend distributions can sit under the gate entirely, while a trading group with far smaller economics sits above it.
Gross, not net, and in both directions
The schedule requires gross income and expenditure to be reported separately, for each related party in aggregate by type. Nothing is netted off.
A UAE entity that buys AED 25 million of goods from an affiliate and sells AED 20 million of services back to it has AED 45 million of aggregate transactions, not AED 5 million. Businesses with modest net intra-group exposure are routinely surprised to find themselves over the AED 40 million line.
The AED 4 million categories
The per-category test uses the transaction types in the schedule's own drop-down list: goods, services, intellectual property, interest, assets, liabilities, and other. A category is tested across all related parties in aggregate, not per counterparty.
So a business with seven affiliates each buying AED 700,000 of services has AED 4.9 million of services and must disclose that category, even though no single relationship is close to the number.
#What the Connected Persons Schedule asks for
The second schedule covers a different population. A connected person under Article 36(2) is an owner of the taxable person, a director or officer, and the related parties of either — so this schedule is about what the business pays the people who run and own it, not about intra-group trading. CTGTXR1 section 16.2 says it is completed only where the aggregate value of transactions with connected persons, including their related parties, exceeds AED 500,000, and then for each connected person above that amount.
| Field | What you enter |
|---|---|
| 16.2.1 Name of the connected person | Legal name |
| 16.2.2 Corporate tax TRN or TIN | Where available, UAE or foreign |
| 16.2.3 Payment or benefit | Selected from a drop-down list |
| 16.2.4 Description | The service provided in return for the payment, or the nature of the benefit given |
| 16.2.5 Value of the payment or benefit | The total for each type of payment or benefit in the tax period, as recorded in the financial statements |
| 16.2.6 Market value of the service or benefit | What would have been paid or given if not dealing with a connected person |
| 16.2.7 Adjustment | Calculated automatically as the difference between 16.2.5 and 16.2.6 |
#The questions everyone answers, threshold or not
Before either schedule appears, section 9.3 of the return puts a short set of questions to all taxable persons — CTGTXR1 marks that part "applicable to all Taxable Persons". They ask whether there were transactions with related parties in the tax period, whether the aggregate exceeded AED 40 million, and whether transactions with connected persons exceeded AED 500,000. Answering yes to the value questions routes you into the schedules.
Upward and downward adjustments are entered by hand
Fields 9.3.3 and 9.3.4 take the aggregate value of adjustments that increase and decrease taxable income. CTGTXR1 is explicit that upward adjustments must not be netted off against downward ones, and that both fields must still be completed manually even where a schedule is being filed — because not every transaction is reported in the schedule, the figure here should be equal to or more than the adjustment shown there.
Downward adjustments are not self-service. The guide states that a transfer pricing adjustment decreasing taxable income is allowed only upon a successful application to the FTA, and that if it is not approved you enter nil. A group planning to reduce UAE taxable income to reach an arm's length result should treat that approval as the gating step, not the return.
Assets received earlier at a non-arm's length price
Question 9.3.5 asks whether any gain or loss was realised in the period on an asset or liability previously received from a related party at a non-arm's length price. Where the answer is yes, fields 9.3.6 and 9.3.7 take the gain or loss determined under Article 3 of Ministerial Decision No. 134 of 2023. Realisation includes sale, disposal, settlement, forgiveness of a liability and complete worthlessness of an asset.
#When it is due, and what to do if you get it wrong
There is no separate disclosure deadline. The schedules are part of the return, and Article 53(1) of the Corporate Tax Law requires the return to be filed and the tax paid within nine months of the end of the tax period. CTGTP1 states the same date for the disclosure form itself.
CTGTXR1 describes the whole return as a self-assessment process, and CTGTP1 adds that the disclosure form is based on the self-assessment model, so the burden sits with the taxable person to ensure the year's transactions were at arm's length. Nobody checks the schedule before it is accepted.
A wrong schedule is corrected the same way as a wrong return
Because the disclosure is part of the return, an error in it is an error in the return, and the correction route is the corporate tax voluntary disclosure procedure rather than a re-filed form.
We are not going to state a penalty figure for a mis-stated schedule specifically. The administrative penalties sit in the Tax Procedures regime and turn on what the error did to the tax due, not on the schedule it appeared in — check the current penalty schedule for the situation you are actually in rather than assuming a fixed amount applies.
#Disclosure is not documentation
Treating the disclosure schedules as the whole transfer pricing compliance job is the most expensive misunderstanding in this area.
CTGTP1 section 6.4 lists five documentation requirements: the disclosure form, the master file, the local file, the country-by-country report, and additional information requested under Article 55(4). A master file and local file are required where the taxable person is in an MNE group with consolidated revenue of AED 3.15 billion or more, or where its own revenue is AED 200 million or more, under Ministerial Decision No. 97 of 2023 — an order of magnitude above the AED 40 million disclosure gate.
The two tests are independent
A business under both thresholds still owes arm's length pricing, because Article 34 has no threshold at all. The most common position is over the disclosure gate and under the documentation one: schedules in the return, no master or local file. The reverse also happens — revenue above AED 200 million while related-party transactions sit below AED 40 million, so the files are required and the schedule may not open.
Sources and legal basis
This page relies on
- Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses
- Article 34 of the Corporate Tax Law (Arm's Length Principle)
- Article 35 of the Corporate Tax Law (Related Parties and Control)
- Article 36 of the Corporate Tax Law (Payments to Connected Persons)
- Article 53 of the Corporate Tax Law (Tax Returns)
- Article 55(1) of the Corporate Tax Law (Transfer Pricing Documentation)
- Ministerial Decision No. 97 of 2023
- Ministerial Decision No. 134 of 2023
- Federal Tax Authority (FTA)
- EmaraTax
- Transfer Pricing Guide CTGTP1
- Tax Returns Guide CTGTXR1
- Related Party Transaction Schedule
- Connected Persons Schedule
- Related Party
- Connected Person
- Market Value
- Arm's Length Value
- Comparable uncontrolled price method
- Resale price method
- Cost plus method
- Transactional net margin method
- Transactional profit split method
- AED 40 million related party disclosure threshold
- AED 4 million per-category disclosure threshold
- AED 500,000 connected person disclosure threshold
- Master file
- Local file
- Voluntary disclosure
- Corporate Tax Guide: Tax Returns (CTGTXR1), November 2024 — sections 9.3 and 16Federal Tax Authority
- Corporate Tax Guide: Transfer Pricing (CTGTP1), October 2023 — section 6.5Federal Tax Authority
- Transfer Pricing Guide CTGTP1 — landing pageFederal Tax Authority
- Federal Decree-Law No. 47 of 2022 and its amendments (consolidated)UAE Ministry of Finance
- Ministerial Decision No. 97 of 2023 on Requirements for Maintaining Transfer Pricing DocumentationUAE Ministry of Finance
Rates, thresholds and deadlines change. Every figure above is linked to the authority that publishes it — if the two ever disagree, the authority is right and this page is out of date. Tell us and we will fix it.
Frequently asked questions
What is the UAE transfer pricing disclosure form?
It is the disclosure of related party and connected person transactions that the FTA requires under Article 55(1) of the Corporate Tax Law. In practice it is delivered as two schedules inside the corporate tax return in EmaraTax: the Related Party Transaction Schedule and the Connected Persons Schedule. Both are filed with the return, not separately, and both open only when a value threshold is exceeded.
Is there a UAE transfer pricing disclosure form PDF to download?
No standalone PDF has been published by the Federal Tax Authority, checked 21 August 2026. The Transfer Pricing Guide CTGTP1 said in October 2023 that a sample would be available on the FTA website in due course; the guide's landing page still carries only the guide itself. The field list is documented instead in the Tax Returns Guide CTGTXR1, sections 9.3 and 16.
What is the threshold for the transfer pricing disclosure form in the UAE?
Three thresholds apply, all from CTGTXR1. The Related Party Transaction Schedule opens where the aggregate value of all transactions with all related parties exceeds AED 40 million. Within it, each transaction category above AED 4 million must be disclosed. The Connected Persons Schedule applies separately where transactions with connected persons, including their related parties, exceed AED 500,000.
Where can I see a sample of the transfer pricing disclosure form?
No official sample exists. Templates circulating from advisory firms are reconstructions of the EmaraTax schedules, not FTA-issued documents, and filing on one satisfies nothing. To see what you will be asked, read sections 16.1 and 16.2 of the Tax Returns Guide CTGTXR1, which set out every field by number, from the counterparty name through to the automatically calculated adjustment.
Does the FTA require the disclosure to be submitted separately from the tax return?
No. The schedules sit in Part I of the corporate tax return and are submitted with it, within nine months of the end of the tax period under Article 53(1) of the Corporate Tax Law. There is no separate submission window, reference number or portal. CTGTP1 describes the disclosure as being submitted alongside the return on the same nine-month clock.
Do dividends between related parties count towards the AED 40 million threshold?
No. CTGTXR1 states that dividends declared between related parties do not need to be disclosed in the Related Party Transaction Schedule and should not be taken into account when determining either the AED 40 million or the AED 4 million threshold. For holding structures whose intra-group flows are largely distributions, that exclusion can keep the schedule closed entirely.