Transfer Pricing ("TP") provisions were introduced in
the UAE along with the Corporate Tax Law. Article 34 of the
Corporate Tax Law requires that transactions or arrangements
between Related Parties must meet the arm's length
standard.
Article 59 of the Corporate Tax Law permits the submission of an
application for an Advance Pricing Agreement ("APA") with
the Federal Tax Authority ("FTA") to determine in advance
the arm's length price ("ALP") with respect to
controlled transactions or arrangements proposed or already entered
into by the taxpayers.
The introduction of the APA Guide by the UAE FTA in December
2025 marks a significant milestone in the evolution of the
UAE's TP and corporate tax landscape. While compliance
requirements such as TP documentation (benchmarking documents,
local file, and master file) and disclosure obligations laid the
foundation of TP in the UAE, taxpayers have continued to seek
greater certainty, particularly for complex and
