Transfer pricing documentation in the UAE: who files what, and when

The three layers

UAE transfer pricing compliance stacks in three layers, and most businesses only owe the first. Layer one: every taxable person with related-party or connected-person dealings must be able to show they were priced at arm's length — that is the substantive rule, and it has no size threshold. Layer two: a disclosure form filed with the Corporate Tax return, summarising related-party and connected-person transactions, required once those transactions cross the ministerial materiality thresholds. Layer three: formal documentation — a master file and local file — required only for the largest taxpayers: broadly, members of multinational groups above the country-by-country threshold (AED 3.15 billion consolidated revenue) or standalone businesses with revenue of AED 200 million or more.

What the disclosure form wants

• Related-party transactions by category — goods, services, IP, financing — with values and the pricing method used
• Connected-person payments: remuneration and benefits to owners, directors and their relatives
• Consistency: the numbers must reconcile to the financial statements the return is built on — a form that disagrees with the ledger is an invitation

What arm's length means in practice

Every intercompany price needs a method you can name — comparable uncontrolled price, cost plus, resale minus, transactional net margin — and evidence that the method's inputs are real: agreements signed before the charges ran, cost bases that reconcile, benchmarks for the margin. The documentation burden scales with size, but the analysis burden doesn't: a two-entity group with one management fee needs the same defensible logic as a multinational, just fewer binders.

The failures that get priced first

• Year-end round-number journals labelled 'management fee' with no agreement behind them
• Free-zone entities at 0% receiving charges that strip mainland profit — the single most examined pattern
• Interest-free intercompany balances left to drift for years — loans need terms, and terms need rates
• Disclosure thresholds tracked nowhere, so nobody knows the form was due until the return is being finalised

How Orbit applies this

Orbit tags related-party and connected-person flows as they post, keeps the agreement and invoice attached to each, accumulates the disclosure-form categories through the year, and shows the totals against the thresholds — so the form is a report at filing time, not a reconstruction.