[1]UAE- Transfer Pricing Compliance Dates
The introduction of UAE Corporate Tax, effective from financial years starting on or after 1 June 2023, brings with it stringent Transfer Pricing Regulations. These regulations mandate that all Related Party Transactions be conducted at arm’s length. The Federal Decree-Law No 47 of 2022 outlines the provisions for these regulations, ensuring transparency and fairness in intercompany transactions.
Applicable Transfer Pricing Provisions:
Transfer Pricing Provisions laid down under Federal Decree-Law. No 47 of 2022
| S N | Particulars | Articles of Federal Decree Law |
| 1. | Arm’s Length Principle | Article 34 |
| 2. | Related Parties | Article 35 |
| 3. | Connected Person | Article 36 |
| 4. | Transfer Pricing Documentation | Article 55 |
Transfer Pricing Compliance
Tax Period:
Article 57 (Tax Period) of UAE Corporate Tax Law states that, “A Taxable Person’s Tax Period is the Financial Year (Gregorian calendar year, or the twelve-month period) or part thereof for which a Tax Return is required to be filed.”
A. Where the first Tax Period is 1 July 2023- 30 June 2024
| Activity | Articles of Federal Decree Law | Remarks | Deadline |
| Tax Return | Article 53 | – | 31-March-2025 |
| Disclosure Format (To be filed with the Tax Return) | Article 55 (1) | Yet to be prescribed by the Federal Tax Authority | 31-March-2025 |
| Local File | Article 55 (2), (3), (4) | 1. Subject to the qualification of conditions prescribed in the Clause (2) of Article (55) of Federal Decree Law which specifies two conditions for maintaining master and local files:
a) the MNE Group’s total consolidated group revenue is AED 3.15 billion or more in the relevant tax period; or b) The taxable person’s revenue in the relevant tax period is AED 200 million or more. If a taxable person meets either of these conditions, they are obligated to maintain both a master file and a local file for the relevant tax period. 2. To be submitted with the Authority within 30 days from the date of request by the said Authority |
31-March-2025 |
| Master File | Article 55 (2), (3), (4) | 31-March-2025 | |
| Country by Country Report | Article 55 | UAE-headquartered Groups of companies which meet the following criteria should comply with CbC Reporting legislation in the UAE:
|
30-June-2025
(Filed within 12 months from the end of the reporting year of the MNE Group) |
(This space has been intentionally left blank)
B. Where the first Tax Period is 1 January 2024- 31 December 2024
| Activity | Articles of Federal Decree Law | Remarks | Deadline |
| Tax Return | Article 53 | – | 30-September-2025 |
| Disclosure Format (To be filed with the Tax Return)
|
Article 55 (1) | Yet to be prescribed by the Federal Tax Authority
|
30-September-2025 |
| Local File | Article 55 (2), (3), (4) | 1. Subject to the qualification of conditions prescribed in the Clause (2) of Article (55) of Federal Decree Law which specifies two conditions for maintaining master and local files:
a) the MNE Group’s total consolidated group revenue is AED 3.15 billion or more in the relevant tax period. b) The taxable person’s revenue in the relevant tax period is AED 200 million or more. If a taxable person meets either of these conditions, they are obligated to maintain both a master file and a local file for the relevant tax period. 2. To be submitted with the Authority within 30 days from the date of request by the said Authority |
30-September-2025 |
| Master File | Article 55 (2), (3), (4) | 30-September-2025 | |
| Country by Country Report | Article 55 | UAE-headquartered Groups of companies which meet the following criteria should comply with CbC Reporting legislation in the UAE:
|
31-December-2025
(Filed within 12 months from the end of the reporting year of the MNE Group) |
(This space has been intentionally left blank)
C. Where the first Tax Period is 1 April 2024- 31 March 2025
| Activity | Articles of Federal Decree Law | Remarks | Deadline |
| Tax Return | Article 53 | – | 31-December-2025 |
| Disclosure Format (To be filed with the Tax Return) | Article 55 (1) | Yet to be prescribed by the Federal Tax Authority | 31-December-2025 |
| Local File | Article 55 (2), (3), (4) | 1. Subject to the qualification of conditions prescribed in the Clause (2) of Article (55) of Federal Decree Law which specifies two conditions for maintaining master and local files:
a) the MNE Group’s total consolidated group revenue is AED 3.15 billion or more in the relevant tax period. b) The taxable person’s revenue in the relevant tax period is AED 200 million or more. If a taxable person meets either of these conditions, they are obligated to maintain both a master file and a local file for the relevant tax period. 2. To be submitted with the Authority within 30 days from the date of request by the said Authority
|
31-December-2025 |
| Master File | Article 55 (2), (3), (4) | 31-December-2025 | |
| Country by Country Report | Article 55 | UAE-headquartered Groups of companies which meet the following criteria should comply with CbC Reporting legislation in the UAE:
|
31-March-2026
(Filed within 12 months from the end of the reporting year of the MNE Group) |
(This space has been intentionally left blank)
Note:-
[1] Federal Decree Law No 47 of 2022
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