The UAE Federal Tax Authority (FTA) has activated its Advance Pricing Agreement (APA) programme on the EmaraTax portal. Following the FTA's Corporate Tax Guide on APAs, released on 31 December 2025, businesses can now file APA pre-filing requests online for domestic related-party transactions, with applications accepted from 30 December 2025.
Key takeaways
- The FTA released its Corporate Tax Guide on Advance Pricing Agreements on 31 December 2025, and the programme is now accessible through the EmaraTax portal.
- Phase 1 is live for domestic unilateral APAs (UAPAs) — typically mainland-to-free zone dealings — with applications accepted from 30 December 2025.
- Cross-border UAPAs, bilateral (BAPA) and multilateral (MAPA) agreements are scheduled for later phases, with dates to be announced during 2026.
- An APA fixes the arm's length price for covered transactions over three to five prospective tax years and binds both the FTA and the taxpayer.
- The minimum threshold is AED 100 million of covered transactions per tax period; the application fee is AED 30,000 and a renewal AED 15,000.
- The process begins with a pre-filing consultation that the FTA aims to review within six to nine months.
What went live on 31 December 2025
Two things went live at the end of 2025. First, the FTA published its formal Corporate Tax Guide on APAs, setting out the eligibility rules, fees and procedure. Second, and just as important for day-to-day practice, the APA process became a live e-service inside EmaraTax, so eligible businesses can lodge a pre-filing request through the portal rather than waiting for a manual channel. In the current phase the door is open to domestic unilateral APAs; cross-border and treaty-based agreements follow later.
An Advance Pricing Agreement is a binding agreement between a taxpayer and the FTA that determines, in advance, the arm's length price for specified related-party (Controlled) transactions — the fee, margin or method that will apply to dealings such as intragroup sales, services, financing or intellectual property. Agreeing this up front removes the transfer pricing uncertainty that otherwise hangs over a business until an audit closes it, years later. To qualify, the covered transactions must generally reach AED 100 million per tax period, and the agreement runs for three to five future years.
The programme is being introduced in phases, so what you can file today depends on the type of transaction:
| Phase | Covers | Status |
|---|---|---|
| Phase 1 | Domestic unilateral APAs (UAPAs), such as mainland-to-free zone dealings | Live; applications accepted from 30 December 2025 |
| Phase 2 | Cross-border unilateral APAs | Date to be announced in 2026 |
| Phase 3 | Bilateral (BAPA) and multilateral (MAPA) agreements | Future phase |
How to file an APA request on EmaraTax
The entry point is the pre-filing consultation, which is mandatory — a formal application can only be filed after the FTA reviews the pre-filing request and invites the business to proceed. Inside the portal the path is short:
- Log in to EmaraTax with UAE Pass at eservices.tax.gov.ae.
- Select the registered taxable person (your entity).
- Open the "Advance Pricing Agreements" section in the left sidebar.
- Submit the pre-filing consultation request form, setting out the proposed transactions, transfer pricing method and key complexities.
- Track the request's status under "View All".
The pre-filing submission carries more weight than groups expect: it is what the FTA uses to judge whether the case is suitable, and a thin scope description gives it little to say yes to — so it is worth investing in before anything formal is filed.
What happens after you file
The FTA reviews the pre-filing request within a target of six to nine months and either invites the business to apply or declines with reasons. Throughout, the business is expected to answer FTA queries within 40 Business Days. Once invited, the full application must be filed within 40 Business Days of the notification, or at least 12 months before the start of the first covered period, whichever is earlier, and is accompanied by the AED 30,000 fee, detailed economic analysis and benchmarking.
The FTA then conducts an in-depth review — which can include site visits, interviews and further information requests — and sets out a project plan for the remaining stages. In evaluation and negotiation, it prepares and shares its own independent transfer pricing analysis, specifying the methods, criteria and assumptions for the covered periods, and the taxpayer responds within 30 Business Days to work towards mutually agreed terms. If no agreement is reached, the case is closed and the fee is not refunded.
A concluded APA is signed by both parties and binds them for three to five prospective tax periods, after which the FTA will not adjust the pricing of covered transactions provided the business complies with the agreed terms and critical assumptions. Compliance is monitored through annual declarations, with mechanisms for revisions, cancellations or renewals as circumstances evolve. Because cross-border flows are not yet in scope, businesses with international dealings should plan the international tax angle early.
Only domestic unilateral APAs are open today. If your related-party transactions cross a border, watch for the cross-border phase expected during 2026 before assuming EmaraTax can cover them now.
Frequently asked questions
How do I apply for an APA on EmaraTax?
Log in to EmaraTax with UAE Pass at eservices.tax.gov.ae, select your registered taxable person, and open the "Advance Pricing Agreements" section in the left sidebar. Submit the pre-filing consultation request form, then track its status under "View All". A pre-filing consultation is mandatory before any formal APA application can be filed.
When did the UAE APA programme open?
The FTA released its Corporate Tax Guide on Advance Pricing Agreements on 31 December 2025 and began accepting applications for domestic transactions from 30 December 2025. The programme is delivered through the EmaraTax portal. Cross-border unilateral APAs and bilateral or multilateral agreements will follow in later phases during 2026.
Which transactions can use the APA programme now?
Only domestic unilateral APAs are open in the current phase — for example, a Qualifying Free Zone Person transacting with a mainland company. Cross-border unilateral APAs, along with bilateral (BAPA) and multilateral (MAPA) agreements, are planned for subsequent phases, with timelines to be announced during 2026.
What does it cost to apply for an APA?
A formal APA application carries a non-refundable fee of AED 30,000, and a renewal costs AED 15,000. The covered related-party transactions must generally reach AED 100 million per tax period. The fee is not returned if the process ends without a concluded agreement, so the quality of the pre-filing submission matters from the outset.
How SBC Tax Consulting can help
Getting onto the EmaraTax APA track well is mostly about the pre-filing submission. SBC's transfer pricing team prepares the scoping request, the functional and economic analysis and the benchmarking the FTA expects, files through the portal, and represents you through review and negotiation. We can also fold the outcome into your broader corporate tax compliance. To start a pre-filing assessment, contact SBC.
This publication is for general information only and does not constitute professional advice. Please consult your SBC advisor before acting on any matter covered here.