UAE issues Transfer Pricing documentation requirements

The UAE Ministry of Finance published Ministerial Decision No. 97 of 2023 on 27 April, which sets out the transfer pricing (TP) documentation requirements for the purpose of the new Corporate Tax Law.

The Decision provides that only taxpayers which are part of a multinational group with consolidated revenues of more than or equal to AED3.15 billion, or taxpayers with more than or equal to AED200 million revenues in the relevant tax period, are required to maintain UAE TP documentation – Master file and Local file.

While the Decision provides relaxation from maintenance of TP documentation for certain set of taxpayers, it does not altogether exempt them from the TP provisions. All entities are still required to undertake transactions with related parties and connected persons at an arm’s length price, for which benchmarking analysis will be needed. The TP Disclosure form will also need to be filed along with return of income showing details of related parties and connected persons transactions,” said Nicholas Cully, Sovereign Group Sales Director.

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