By September 30, 2025, UAE businesses falling under corporate tax must have their FY 2024 audited financial statements finalised, ensure transfer pricing adjustments are in place, and submit the necessary related-party disclosures.
Let us dive into what businesses need to prepare ahead of the upcoming September filing deadlines under the UAE’s transfer pricing regime – what is required, the risks of non-compliance, and how to turn these obligations into a strategic advantage.
Since Inception: From New Rules to Real Deadlines
When the UAE introduced corporate tax and transfer pricing (“TP”), it marked a major shift from its traditionally low-tax environment. Businesses have since been adjusting to these rules but with the first real deadlines now here, compliance is heating up.
What’s Due in September – A Transfer Pricing Perspective
By September, businesses must ensure they are ready to meet the Federal Tax Authority (“FTA”)’s filing and documentation requirements. These include:
- TP Disclosure Form submitted alongside the corporate tax returns, where thresholds are met as follows:
- AED 40 million in total related transactions triggers full TP disclosure
- AED 4 million per transaction category (e.g., goods, services, interest) must be detailed once the AED 40 million threshold is reached.
- AED 500,000 in transactions with connected persons also triggers reporting.
- Maintain supporting TP documentations (Master File and Local File) where thresholds are met as follows:
- Part of MNE with consolidated revenue at least AED 3.15 billion; or
- Legal entity with revenue at least AED 200 million.
- Benchmarking studies, functional and economic analyses to demonstrate transactions are at arm’s length; and
- Ensure consistency across tax returns, disclosure forms, financial statements, and legal agreements.
Failure to prepare properly can trigger audits, penalties, and reputational risks. Even minor inconsistencies across forms and supporting documents may raise red flags with the FTA.
What Tax Authorities Are Focusing On
With TP audits already underway in 2025, the FTA is focusing on:
- High-value cross-border transactions
- Intangible-related transfers such as IP, management fees, and brand use
- Loss-making entities and those showing abnormal profit fluctuations
- Loans and financing structures
- Free zone hubs with weak substance
Perhaps the most common audit trigger is simply inconsistency. If the numbers in your TP disclosure form do not align with your Local File, financial statements, or legal agreements, expect questions. Even small discrepancies can open the door to deeper investigation.
Beyond Compliance: Turning TP into an Opportunity
While September’s filings are about compliance, TP is also a strategic tool. Businesses that embed TP into operations can:
- Optimise their operating models
- Align tax outcomes with commercial strategy
- Strengthen governance and investor confidence
- Protect their reputation through transparent tax practices
Conclusion
The UAE’s TP rules are no longer new and with the September deadline approaching fast, businesses need to act now. Those that prepare early, with strong evidence and substance, will not only stay audit-ready but also position themselves for long-term strategic advantage. Get in touch if you’d like help to get your documentation in line.
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