Transfer pricing disclosure form
- Applies
- FY2024 onwards
- Reviewed
- Rule
- UAE-CT-TPDISC-2024.1
Who must file the UAE transfer pricing disclosure form?
A taxpayer with Related Party transactions over AED 40 million in total, or paying a Connected Person over AED 500,000.
Per Federal Decree-Law No. 47 of 2022, Article 55(1), Transfer Pricing Documentation
The Authority may, by notice or decision, require a Taxable Person to file with its Tax Return a disclosure of its transactions and arrangements with Related Parties and Connected Persons. The prescribed Tax Return requires the Related Parties schedule where the aggregate of all Related Party transactions exceeds AED 40 million, the Connected Persons schedule for each Connected Person whose payments or benefits exceed AED 500,000, and disclosure of every transaction carrying a downward transfer pricing adjustment, whatever its value.
Filed with the Tax Return, so the return's deadline governs. Below every trigger nothing is disclosed, but the transactions must still be at arm's length and supported on request under Article 55(4).
What triggers a disclosure
55(1) — the power
The Authority may, by notice or through a decision, require a disclosure with the Tax Return, in the form it prescribes. It has done so through the Tax Return form itself.
The Tax Return's triggers — Tax Returns Guide (CTGTXR1)
- Related Parties schedule: where the aggregate value of all transactions with all Related Parties in the period, as recorded or at Market Value, exceeds AED 40 million
- Connected Persons schedule: for each Connected Person whose aggregate payments or benefits, with its Related Parties, exceed AED 500,000
Downward adjustments — public clarification CTP011 (July 2026)
A Taxable Person self-assesses transfer pricing adjustments in the return, upward or downward, without prior approval. Every transaction on which a downward adjustment is made must be disclosed, irrespective of value or nature — and the file should hold the rationale, a benchmarking study, a reconciliation to the financial statements, and evidence of the Related Party's symmetrical corresponding adjustment.
A notice
A notice the Authority addresses to a Taxable Person is a separate route, whatever the figures.
The deadline is the return's
Because the disclosure is filed together with the Tax Return. That is a different date from the window Article 55(3) and (4) give for producing the master and local file, or supporting information, after a request — and conflating them gives the wrong date.
Order of testing
- 1
Inputs requiring your determination
Any input a person must decide and has not decided stops the computation.
- 2
Transactions with Related Parties or Connected Persons
Nothing to disclose without them.
- 3
The Tax Return's disclosure triggers
The Related Party aggregate against the published amount, the largest Connected Person aggregate against its published amount (both 'exceeds'), any downward adjustment, and any notice. Any one triggers the disclosure.
Examples
Illustrative scenarios — ours, not the authority’s — each computed live by this rule. Change any fact and the outcome is the rule’s, not a hand-written answer.
A large group company
Related Party transactions of AED 45 million in the year, disclosed with the return.
Computed
A disclosure under Article 55(1) is required as computed: the Related Parties schedule, as the aggregate of AED 45,000,000 exceeds AED 40,000,000. You have indicated it has been filed with the Tax Return. The disclosure is filed with the Tax Return, so the return's deadline governs it — not the window for producing the master file, local file or supporting information on request under Article 55(3) and (4). Whether its content satisfies the prescribed form is not something this rule tests.
Workings
- Aggregate Related Party transactionsas supplied
- AED 45,000,000
- Related Parties schedule thresholdpublished value for FY2026
- AED 40,000,000
- Largest aggregate for one Connected Personas supplied, with its Related Parties
- AED 0
- Connected Persons schedule thresholdpublished value for FY2026
- AED 500,000
- Related Parties schedule triggered1 where the aggregate exceeds the published value
- 1
- Connected Persons schedule triggered1 where one Connected Person's aggregate exceeds the published value
- 0
Decided by the tax return's disclosure triggers
Director's fees above the Connected Person amount, not disclosed
A private company pays its owner-director AED 900,000 and has AED 5 million of Related Party transactions.
Computed
A disclosure under Article 55(1) is required as computed: the Connected Persons schedule, as at least one Connected Person's aggregate of AED 900,000 exceeds AED 500,000. You have indicated it has not been filed with the Tax Return. The disclosure is filed with the Tax Return, so the return's deadline governs it — not the window for producing the master file, local file or supporting information on request under Article 55(3) and (4).
Workings
- Aggregate Related Party transactionsas supplied
- AED 5,000,000
- Related Parties schedule thresholdpublished value for FY2026
- AED 40,000,000
- Largest aggregate for one Connected Personas supplied, with its Related Parties
- AED 900,000
- Connected Persons schedule thresholdpublished value for FY2026
- AED 500,000
- Related Parties schedule triggered1 where the aggregate exceeds the published value
- 0
- Connected Persons schedule triggered1 where one Connected Person's aggregate exceeds the published value
- 1
Decided by the tax return's disclosure triggers
A small downward adjustment
A company overcharged a Related Party AED 300,000 and adjusts its Taxable Income down in the return. The value is small, but a downward adjustment is always disclosed.
Computed
A disclosure under Article 55(1) is required as computed: a disclosure of every transaction carrying a downward adjustment, irrespective of value (CTP011). You have indicated it has been filed with the Tax Return. The disclosure is filed with the Tax Return, so the return's deadline governs it — not the window for producing the master file, local file or supporting information on request under Article 55(3) and (4). Whether its content satisfies the prescribed form is not something this rule tests.
Workings
- Aggregate Related Party transactionsas supplied
- AED 3,000,000
- Related Parties schedule thresholdpublished value for FY2026
- AED 40,000,000
- Largest aggregate for one Connected Personas supplied, with its Related Parties
- AED 0
- Connected Persons schedule thresholdpublished value for FY2026
- AED 500,000
- Related Parties schedule triggered1 where the aggregate exceeds the published value
- 0
- Connected Persons schedule triggered1 where one Connected Person's aggregate exceeds the published value
- 0
Decided by the tax return's disclosure triggers
Below every trigger
AED 8 million of Related Party transactions, no Connected Person above AED 500,000, and no downward adjustment.
Computed
No transfer pricing schedule is triggered as computed: the Related Party aggregate of AED 8,000,000 does not exceed AED 40,000,000, no Connected Person's aggregate exceeds AED 500,000, no downward adjustment is made, and no notice has been received. The transactions must still meet the arm's length standard (Article 34), and Article 55(2) to (4) may still apply. Based on the figures you supplied.
Workings
- Aggregate Related Party transactionsas supplied
- AED 8,000,000
- Related Parties schedule thresholdpublished value for FY2026
- AED 40,000,000
- Largest aggregate for one Connected Personas supplied, with its Related Parties
- AED 200,000
- Connected Persons schedule thresholdpublished value for FY2026
- AED 500,000
- Related Parties schedule triggered1 where the aggregate exceeds the published value
- 0
- Connected Persons schedule triggered1 where one Connected Person's aggregate exceeds the published value
- 0
Decided by the tax return's disclosure triggers
Try it
Supply the facts and this rule computes the outcome in your browser, live. Leave a determination undecided and it blocks the result — it is never read as a no.
Not computed yet
1 input still need your determination:
- Were there transactions or arrangements with Related Parties or Connected Persons in the period?
Computed in your browser from the figures you supply. Nothing is sent anywhere, and the result is a computation against a rule — reference, not tax advice.
Thresholds
- uae.tp_disclosure_related_party_aggregate
- AED 40,000,000 · reviewed 2026-09-28 · source
- uae.tp_disclosure_connected_person_aggregate
- AED 500,000 · reviewed 2026-09-28 · source
Threshold values are published separately from the rule and carried with a citation. Where none has been published for the period being computed, the rule reports that rather than applying a default.
Sources
Federal Decree-Law No. 47 of 2022, Article 55(1) — Transfer Pricing Documentation
The power this rule encodes
https://mof.gov.ae/wp-content/uploads/2022/12/Federal-Decree-Law-No.-47-of-2022-EN.pdfFTA — Tax Returns Guide (CTGTXR1)
The Tax Return's Related Parties and Connected Persons schedules and their thresholds (questions 9.3.2 and 9.3.9, section 16)
https://tax.gov.ae/Datafolder/Files/Guides/CT/CT-Returns-EN-11-11-2024.pdfFTA — Public Clarification CTP011: downward adjustments made by a Taxable Person in the Tax Return
Every transaction carrying a downward adjustment is disclosed, irrespective of value
https://tax.gov.ae/en/taxes/corporate.tax/corporate.tax.guides.references.aspxFTA — Transfer Pricing Guide (CTGTP1)
The Authority's guidance on the disclosure form
https://tax.gov.ae/Datafolder/Files/Pdf/2023/Transfer%20Pricing%20Guide%20-%20EN%20-%2023%2010%202023.pdf