Valusage Business Advisors
Transfer Pricing6 min read

Article 55 UAE Transfer Pricing: Local & Master File Rules

By Valusage Technical Practice

Editorial responsibility: Valusage Business Advisors Editorial Practice

Local File and Master File documentation beside a related-party transaction map.
Transfer Pricing guidance supported by an original editorial image and a separate decision graphic.

Direct answer

A UAE transfer-pricing review should identify related-party transactions, understand the functions, assets and risks involved, test the pricing against an arm’s-length framework, and determine what documentation or disclosure is required for the relevant entity and period. The applicable thresholds and filing position must be verified against current rules.

Advisory decision map

From information to a controlled decision

  1. 01Question
  2. 02Evidence
  3. 03Options
  4. 04Action

Illustrative evidence trend

Decision support
QuestionEvidenceOptionsAction
This title-specific graphic explains a review sequence. It does not represent client performance, authority acceptance, or an assured outcome.

Under Article 55 of the UAE Corporate Tax Law, related-party transactions must comply with the Arm’s Length Principle. A transfer-pricing review should begin with the related-party and connected-person map, transaction descriptions, functions-assets-risks analysis, pricing evidence, documentation requirements and the entity’s current filing position. Thresholds and documentation obligations must be checked against current law and Federal Tax Authority guidance.

Related control guidance

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Professional boundary

This article is general information. It is not a filing opinion, legal advice, audit conclusion, investment recommendation or guarantee of authority acceptance or commercial outcome.

What is the first step in a UAE transfer-pricing review?+

Map related parties, connected persons, transactions, functions, assets, risks and the relevant tax-period documentation position.

Does every related-party transaction require the same documentation?+

No. Requirements depend on the entity, transaction profile, relevant thresholds, tax period and current rules.

Can a transfer-pricing review guarantee that the FTA will accept a position?+

No. A review organises evidence and applies the relevant framework, but it cannot guarantee an authority outcome.

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