UAE Transfer Pricing Disclosure Form: Step-by-Step Guide

The UAE Transfer Pricing Disclosure Form is not a separate filing — it is a set of schedules embedded in the Corporate Tax Return, triggered by two independent materiality thresholds: AED 40 million for Related Party transactions and AED 500,000 for Connected Person payments. Getting the mechanics right matters, because the Disclosure Form is often the FTA's first data point for identifying transactions that deserve a closer look.

Since UAE Corporate Tax began, businesses transacting with Related Parties or Connected Persons have completed these schedules inside the return filed on EmaraTax. The form does not require submission of a full transfer pricing report, Local File or Master File at filing stage — but it does require an accurate, well-supported summary of controlled transactions. This guide covers what the form includes, the thresholds, the data the FTA expects, and a practical process for completing it.

What is the UAE Transfer Pricing Disclosure Form?

The Disclosure Form refers to the Related Party Transaction Schedule and the Connected Persons Schedule that form part of the UAE Corporate Tax Return. These schedules were formalised in the FTA's Corporate Tax Guide on Tax Returns (CTGTXR1), released in November 2024, which introduced detailed guidance on how Taxable Persons should report Related Party and Connected Person transactions as part of their annual filing.

The Disclosure Form is a reporting mechanism, not a substitute for underlying transfer pricing compliance. A transaction that falls below the disclosure thresholds still needs to be priced at arm's length under Articles 34 to 36 of Federal Decree-Law No. 47 of 2022. The thresholds only determine whether that transaction must be itemised in the return. What must be reported, and how the thresholds work, is also covered in what businesses need to report.

Who needs to complete the Disclosure Form?

Any UAE Taxable Person — including mainland companies, Free Zone Persons and Qualifying Free Zone Persons, branches and permanent establishments of foreign entities, and individuals carrying on a Business or Business Activity that exceeds the relevant turnover threshold — that has Related Party or Connected Person transactions in a Tax Period should assess whether the disclosure thresholds are met.

Even Taxable Persons applying Small Business Relief or benefiting from Free Zone incentives should confirm whether Related Party and Connected Person disclosure obligations still apply for the relevant Tax Period. Domestic related-party transactions can trigger the same schedules.

What are the two materiality thresholds?

The two thresholds are independent of each other and should be tested separately. A business can be below the AED 40 million Related Party threshold while still being required to disclose a Connected Person payment above AED 500,000, and vice versa.

Schedule	Trigger	What is disclosed
Related Party transactions	Aggregate Related Party transactions exceed AED 40 million	Each category above AED 4 million, disclosed separately
Connected Persons	Aggregate payments to a Connected Person (with that person's Related Parties) exceed AED 500,000	Nature, value and Market Value basis of the payments or benefits

Dividends between Related Parties are excluded from both the AED 40 million and AED 4 million disclosure thresholds.

What is the secondary AED 4 million category threshold?

Once the AED 40 million aggregate Related Party threshold is exceeded, the Related Party Transaction Schedule requires further itemisation. Any individual transaction category — for example Goods, Services, Interest or Intellectual Property — with an aggregate value exceeding AED 4 million in the Tax Period must be separately disclosed with category-specific detail.

Categories that remain below AED 4 million, even where the overall AED 40 million threshold is exceeded, are not required to be itemised individually in the same level of detail.

What data does the Related Party Transaction Schedule require?

For each disclosable Related Party transaction category, the FTA return guidance generally requires details such as:

Name of the Related Party and its tax residence.
The Related Party's Corporate Tax Registration Number, where applicable.
The nature and category of the transaction (Goods, Services, Intellectual Property, Interest, Assets, Liabilities, Other).
Gross income or expense associated with the transaction for the Tax Period.
The transfer pricing method applied to test the transaction.
The arm's length value determined for the transaction.
Any transfer pricing adjustment made to align the recorded value with the arm's length value.

Where a transaction is not recorded at arm's length in the financial statements, a transfer pricing adjustment may be required, and this adjustment generally needs to be reported manually rather than derived automatically from the accounting records.

What does the Connected Persons Schedule require?

Where the AED 500,000 threshold is exceeded for a Connected Person, the schedule generally requires the nature of the payment or benefit, its value, and confirmation that the payment reflects Market Value consistent with Article 36.

Because Connected Person payments often involve remuneration, rent, management fees or loan terms, the supporting basis for Market Value should be prepared well before the filing deadline. After FTA Public Clarification CTP010, director and officer status follows actual authority. See Connected Persons under UAE Corporate Tax.

How should a business prepare the Disclosure Form, step by step?

Step 1 — Map all Related Party and Connected Person relationships. Build a complete list under Articles 35 and 36, cross-checked against ownership structure, board composition and delegation of authority. Do not rely solely on financial-statement related-party notes, which are prepared for accounting purposes and may not align with the Corporate Tax definitions. Start with how to identify Related Parties.

Step 2 — Identify and categorise every transaction. List every transaction or arrangement with each Related Party and Connected Person during the Tax Period, and allocate it to the correct category — Goods, Services, Intellectual Property, Interest, Assets, Liabilities, Other, or a Connected Person payment or benefit. Transactions aggregated in the accounting records may need to be disaggregated for disclosure.

Step 3 — Test the AED 40 million and AED 500,000 thresholds. Total all Related Party transactions against AED 40 million, and separately test the aggregate payment or benefit to each Connected Person (together with their Related Parties) against AED 500,000. Where AED 40 million is exceeded, test each category against AED 4 million.

Step 4 — Confirm the arm's length position for disclosable transactions. For each transaction that must be disclosed, confirm the method applied, the arm's length value, and whether any adjustment is required. This typically draws on benchmarking studies, intercompany agreements and, where applicable, simplified approaches for qualifying low value-adding services.

Step 5 — Populate the schedules on EmaraTax. Enter counterparty details, Tax Registration Numbers, transaction categories, values, methods and adjustments into the relevant schedules within the Corporate Tax Return, ensuring the figures reconcile to the financial statements and working papers.

Step 6 — Reconcile and review before submission. Reconcile the values entered to the financial statements, the general ledger and any transfer pricing documentation prepared for the period. Inconsistencies between the Disclosure Form and the financial statements are a common trigger for further FTA enquiry.

Step 7 — Retain supporting documentation. Detailed reports, Local Files and Master Files are not submitted with the return, but the FTA can request them. Retain the benchmarking analysis, intercompany agreements and calculation workings, generally for a minimum of seven years. Where a Local File is required, see what a UAE Local File should contain.

When must the Disclosure Form be filed?

The Disclosure Form is filed together with the Corporate Tax Return, which is due within nine months from the end of the relevant Tax Period. For a Taxable Person with a 31 December 2025 Tax Period end, for example, the return and the accompanying Disclosure Form schedules would ordinarily be due by 30 September 2026, unless the FTA specifies otherwise for a particular case.

What happens if the Disclosure Form is filed incorrectly or late?

Errors or omissions fall within the general Corporate Tax administrative penalty framework under Cabinet Decision No. 75 of 2023, as amended. Late filing of the Corporate Tax Return (which carries the Disclosure Form) attracts monthly penalties.

Failure to maintain the records and information needed to support the disclosure — including transfer pricing documentation — can separately trigger a penalty of AED 10,000 per violation, rising to AED 20,000 for a repeated violation within 24 months.

Where an error is identified after filing, a Voluntary Disclosure should be considered to correct the position and reduce exposure to higher penalties on audit.

What are common mistakes when completing the Disclosure Form?

Relying on financial-statement related-party notes without independently applying the Article 35 and Article 36 definitions.
Testing the AED 40 million and AED 500,000 thresholds together instead of separately.
Missing the AED 4 million per-category threshold once the AED 40 million aggregate threshold is exceeded.
Treating transactions below the thresholds as automatically compliant, without applying the arm's length principle.
Failing to reconcile Disclosure Form figures to the financial statements and general ledger.
Leaving benchmarking and supporting documentation until after the Corporate Tax Return has already been filed.
Overlooking Connected Person benefits that are non-cash in nature, such as housing, vehicles or other perquisites.

Frequently asked questions

Is the Transfer Pricing Disclosure Form a separate filing from the Corporate Tax Return?

No. It consists of schedules within the Corporate Tax Return filed on EmaraTax, not a stand-alone form filed separately.

What happens if Related Party transactions are below AED 40 million?

The Related Party Transaction Schedule is not required to be completed, but Related Party transactions of any value must still be priced at arm's length.

Do I need to submit a benchmarking study with the Disclosure Form?

No. Detailed benchmarking studies, Local Files and Master Files are not submitted at filing stage, but must be produced to the FTA within 30 days of a request, subject to any extension the FTA may agree.

Can the AED 40 million and AED 500,000 thresholds both apply to the same business?

Yes. A business can be required to complete both schedules, one schedule only, or neither, depending on the value of its Related Party transactions and Connected Person payments in the Tax Period.

Does filing the Disclosure Form guarantee that pricing is accepted?

No. The Disclosure Form is a reporting tool. The FTA retains the ability to review and challenge the pricing of any disclosed or non-disclosed transaction during an audit.

Primary sources and further reading

How SBC Tax Consulting can help

SBC's transfer pricing team maps counterparties, tests the AED 40 million, AED 4 million and AED 500,000 thresholds independently, and populates EmaraTax schedules that reconcile to the ledger and the Local File. Corporate tax specialists file the same figures in the return. Contact SBC before the next 30 September deadline.

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.