UAE Corporate Tax Transfer Pricing Reference 2026 — Related Party Rules
UAE Corporate Tax introduces transfer pricing rules for related party transactions. Here is the complete 2026 reference guide.
In this guide:
What Is Transfer Pricing (TP)?
- Transfer pricing: Rules governing how prices are set for transactions between related parties (companies in the same group)
- UAE CT requirement: All related party transactions must be at arm length — the same price that unrelated parties would agree
- Purpose: Prevent profit shifting; ensure tax is paid where value is created
Who Do UAE TP Rules Apply To?
- Any UAE business with related parties: If your UAE free zone company transacts with affiliated entities (same ownership, control, or family relationship)
- Intragroup transactions: Services, goods, loans, royalties, IP licences between related companies
Arm Length Standard
- Comparable uncontrolled price: What would an unrelated party pay for the same goods/services?
- Cost plus: Cost of providing service + reasonable profit margin
- Transactional net margin method: Net margin compared to unrelated companies in similar transactions
TP Documentation Requirements
- Disclosure form: UAE CT return requires disclosure of related party transactions
- Master file: Required for companies with group revenue above EUR 3.15 billion
- Local file: Required for companies with revenue above AED 200 million or related party transactions above AED 3 million
- CbCR: Country-by-Country Report required for multinational groups with EUR 750 million+ revenue
Common Free Zone TP Scenarios
- Management fees: UAE free zone pays management fee to foreign parent; must be arm length
- Intercompany loans: UAE free zone borrows from related party; interest rate must be market rate
- IP royalties: Royalty paid to related IP-holding company; must be arm length royalty rate