For businesses in the UAE with a 31 December year-end, 30 September is now an established date in the corporate tax calendar. However, as taxpayers enter the second transfer pricing compliance cycle, the significance of this deadline is changing.
Three distinct obligations converge on that date:
Disclosure ("what is reported"): The Transfer Pricing Disclosure Form (TPDF) is submitted with the corporate tax return, with schedules triggered by transaction value.
Documentation ("what is maintained"): A Master File and a Local File must be maintained under Ministerial Decision No. 97 of 2023, with the obligation triggered by revenue. Neither file accompanies the return. Both must be produced within 30 days of a request from the Federal Tax Authority (FTA), or by such later date as the authority directs.
FY2024 was, for many businesses, an implementation exercise. Finance and tax teams had to familiarize themselves with the new UAE corporate tax and transfer pricing requirements, identify related-party transactions, prepare the TPDF and establish initial documentation processes. In many cases, this was managed as a one-off compliance project.
FY2025 presents a different challenge. The second filing cycle provides the FTA with an opportunity to assess whether the positions reported in the first year were consistently applied, whether the underlying data can be reconciled, and whether the documentation reflects the actual commercial arrangements of the business.
The compliance question is therefore evolving. It is no longer simply whether a taxpayer has filed its TPDF correctly, but whether it can substantiate the position reported in that filing through underlying financial data, contractual arrangements and evidence of commercial activity.
This shift from first-time compliance to sustainable governance is likely to be one of the defining features of the UAE transfer pricing environment as the FTA's audit activity develops.
