Transfer Pricing Documentation And Disclosures In Uae

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Transfer Pricing Documentation and disclosures in UAE

All taxpayers that entered into transactions or arrangements with their Related Parties and Connected Persons needs to prepare the Disclosure Form. The Disclosure Form should be file together with the corporate income tax return.

To this date, the precise details and structure of the disclosure form is yet to be confirmed by the FTA.

Transfer Pricing Documentation requirements

Subject	Description
Who must prepare TP Documentation?	ALL UAE taxpayers (foreign owned and domestically owned enterprises) that entered into domestic (between mainland and free zone entities) & cross-border transactions with its Related Parties and Connected Persons.
Type of TP documentation that needs to be prepared?	Both Master File and Local File, subject to following conditions: Taxpayers have revenues in a relevant tax period of at least AED 200 million Or taxpayers are part of a MNE Group with a total consolidated group revenue of at least AED 3.15 billion in the relevant tax period.
When to submit?	Within 30 days from the date of request.
What are the transactions to be included in Local File?	Subject to exclusions set out below, the taxpayers shall include transactions or arrangement with all of the following Related Parties and Connected Persons in the Local File: A non-resident person. An exempt person. A resident person that has made an election for Small Business Relief under Article 21 of the CT Law and meets the conditions of such election. A resident person whose income is subject to different tax rate from that applicable to the income of the Taxable Person (for example transactions between mainland Taxable Person and a Qualifying Free Zone Person).
What are the transactions to be excluded from Local File?	The taxpayers shall not include transactions or arrangements with the following Related Parties and Connected Persons in the Local File: Resident persons other than those specified in paragraph (b), (c) and (d) above. A natural person, provided that the parties to the transaction or arrangement are acting as if they were independent of each other. A juridical person that is considered to be a Related Parties or a Connected Persons solely by virtue of being a partner in an Unincorporated Partnership, provided that the parties to the transaction or arrangement are acting as if they were independent of each other. A Permanent Establishment of a Non-Resident Person in the State whose income is subject to the same Corporate Tax rate as that applicable to the income of the Taxable Person.

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