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ARTICLE · 15 APRIL 2025

Transfer Pricing Rules In The UAE

KINANIS LLC
KINANIS LLC
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KINANIS LLC

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The UAE introduced Transfer Pricing ("TP") regulations as part of its Corporate Tax Law under Federal Decree-Law No. 47 of 2022, which applies to tax periods starting on or after 1 June 2023.

CyprusTax
Marios Palesis
Marios Palesis
Theodora Charalambous
Theodora Charalambous
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The UAE introduced Transfer Pricing ("TP") regulations as part of its Corporate Tax Law under Federal Decree-Law No. 47 of 2022, which applies to tax periods starting on or after 1 June 2023. Businesses must comply with these rules to ensure that transactions between related parties are conducted at arm's length (fair market value).

Key legal references for TP compliance:

  • Corporate Tax Law
  • Ministerial Decision No. 97 of 2023
  • OECD Transfer Pricing Guidelines

Who Must Follow Transfer Pricing Rules?

TP rules apply to all taxable businesses that engage in transactions with Related Parties or Connected Persons. Even if a business is exempt from tax or qualifies for small business relief, it must still follow TP rules but may not be required to maintain full TP documentation.

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