Transfer Pricing Under UAE Corporate Tax: Scope, Relationships And Practical Application

Introduction

Few aspects of the UAE Corporate Tax regime illustrate the shift from formal legal analysis to economic analysis as clearly as Transfer Pricing. Although often associated with multinational groups and cross-border structuring, the UAE rules are framed more broadly. They extend into domestic relationships, closely held entities, and internal business arrangements in a way that materially widens the tax analysis required of businesses operating in the State.

That breadth is evident from Articles 34 to 36 of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (the “Corporate Tax Law”). These provisions do not treat Transfer Pricing as a narrow international tax rule. Rather, they establish a general framework through which the pricing and value of certain relationships and arrangements are tested by reference to statutory standards. In doing so, they require businesses to look beyond legal form and consider how value is created, how functions