Corporate Tax
As per the Public Consultation Document released on the Corporate tax, businesses may be required to pay 9% tax on profits above AED 375,000.
We can support you with:
b) Transfer Pricing Advisory
c) Withholding Tax Advisory
d) Double Taxation Avoidance Agreement Advisory
e) Tax Residency Advisory

Transfer pricing in the UAE

On 11 May 2023, the UAE MoF published Ministerial Decision No. 97 of 2023 on the requirements for preparing and maintaining TP documentation under the UAE CT regime, as defined under Article 55(2) of the Federal Decree-Law No. 47 of 2022 (the CT law).
The application of UAE TP will apply to all UAE taxpayers. All must:
- Comply with the arm’s length principle on related party transactions regardless of CT grouping positions, whether the entity is located in a free trade zone or the rate of CT applicable.
- File a TP disclosure form, as part of their CT return file, with the exception of those claiming Small Business Relief.
Finally, all UAE taxpayers located in UAE free zones are required to comply with the arm’s length principle. Therefore, KPMG recommends free zone entities also prepare supporting local and master files.
Our transfer pricing services
Transfer pricing adventure and risk assessment
- Transfer pricing risk reviews and impact assessments: transfer pricing risk reviews and impact assessments will involve evaluating the potential risks within the intercompany transactions. We will assess if the intercompany pricing aligns with the arm’s length principle, ensuring compliance and best practices. By identifying risks and their impact, multinational groups operating in the UAE can mitigate issues and adjust their pricing strategies to avoid potential future disputes with tax authorities.
- Transfer pricing planning and modelling: transfer pricing planning and modelling of pricing for intercompany transactions within multinational groups, ensuring compliance with tax laws, optimizing profits and minimizing future disputes through strategic pricing structures and financial simulations.
- Tax optimization and business transformation: transfer pricing tax optimization minimizes tax liabilities by strategic pricing in line with value creation. Business transformation adjusts pricing to match evolving business models and operations, ensuring transfer pricing remains effective and compliant with changing market conditions and regulations.
Transfer pricing adventure and risk assessment
- Transfer pricing risk reviews and impact assessments: transfer pricing risk reviews and impact assessments will involve evaluating the potential risks within the intercompany transactions. We will assess if the intercompany pricing aligns with the arm’s length principle, ensuring compliance and best practices. By identifying risks and their impact, multinational groups operating in the UAE can mitigate issues and adjust their pricing strategies to avoid potential future disputes with tax authorities.
- Transfer pricing planning and modelling: transfer pricing planning and modelling of pricing for intercompany transactions within multinational groups, ensuring compliance with tax laws, optimizing profits and minimizing future disputes through strategic pricing structures and financial simulations.
- Tax optimization and business transformation: transfer pricing tax optimization minimizes tax liabilities by strategic pricing in line with value creation. Business transformation adjusts pricing to match evolving business models and operations, ensuring transfer pricing remains effective and compliant with changing market conditions and regulations.
Transfer pricing compliance
Disclosure form: a transfer pricing disclosure form is a form that taxpayers are required to submit to tax authorities, alongside the CT return. It provides information about the company’s intercompany transactions, transfer pricing methods and related parties involved. This form ensures transparency and compliance with tax regulations by providing authorities with insight into the company’s transfer pricing practices. Tax authorities typically use these forms as a risk assessment tool in order to determine what taxpayers to audit.
Local file: an OECD compliant local file is a document prepared by companies to illustrate their compliance with the arm’s length principle. It contains detailed information about the company’s intercompany transactions with related parties within a specific jurisdiction. This file typically includes financial data, descriptions of products or services, transfer pricing methods applied and an analysis demonstrating that the pricing is consistent with the arm’s length principle. In the UAE, companies subject to certain thresholds are required to annually prepare a local file and this should be provided to the UAE tax authority within 30 days upon request.
Master file: a transfer pricing master file gives an overview of a multinational group’s global operations, its organizational structure and its overall transfer pricing policies. This file contains high-level information that applies to all the group’s global operations and presence across different jurisdictions. It helps tax authorities understand the company’s transfer pricing practices on a global scale and facilitates risk assessment and consistency analysis across various transactions and jurisdictions.
Country-by-country reporting: providing financial data that multinational group’s with global turnover above EUR750m (or AED3.15b) annually prepare and submit to tax authorities. This report provides a jurisdictional breakdown of the group’s operations, financial performance, and transfer pricing arrangements in each country where it operates. It includes information such as revenue, profits, taxes paid, and other key economic indicators. The purpose of this report is to provide tax authorities with insight into how the group’s profits are allocated and taxes are paid across different jurisdictions, promoting transparency and ensuring compliance with OECD guidelines and international standards.
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