Transfer pricing is no longer just for multinationals. Under UAE corporate tax, any business that deals with related parties or pays its owners and directors needs to price those dealings at market value and be able to show it.
The two rules
- Arm's length (Article 34). Transactions with related parties must be priced as independent parties would price them.
- Connected persons (Article 36). Payments to owners, directors and officers, and their related parties, are deductible only up to market value and only if made wholly for the business. The FTA clarified in 2026 who counts as a director or officer; an officer is judged by what the person actually does, not their title.
Documentation thresholds
- Master file and local file: required if the UAE entity's revenue is AED 200 million or more, or the group's is AED 3.15 billion or more (Ministerial Decision 97 of 2023).
- Transfer pricing disclosure form: filed with the corporate tax return when related-party transactions exceed AED 40 million, or payments to connected persons exceed AED 500,000.
Below those thresholds you still need to price at arm's length. You simply have less to file.
Where valuation comes in
Many of the hardest transfer pricing questions are valuation questions:
- moving shares, a brand or IP between group companies
- intra-group loans and guarantees
- management fees and cost recharges
- transfers that may qualify for business restructuring relief
An independent valuation is often the simplest way to evidence market value if the FTA asks.
How iConsult can help
Our team of former Big 4 valuation specialists values shares, intangibles and intra-group transactions to the standard auditors and tax authorities expect. See valuation services or book a free consultation.
This article is general information, not legal or tax advice. It reflects the rules as we understand them on the date shown; laws and guidance change, so check the current position or talk to us before you act.