Transfer pricing in the United Arab Emirates concerns how Related Party transactions and Connected Person arrangements are priced and evidenced for UAE Corporate Tax purposes under the arm's length principle. The core rule is Article 34 of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, which requires transactions and arrangements with Related Parties and Connected Persons to meet the arm's length standard.
In operational terms, the UAE framework combines mandatory transfer pricing disclosure with a threshold-based Action 13-style master file and local file regime. The arm's length principle applies to all taxable persons undertaking related-party or connected-person arrangements, regardless of size. However, the obligation to maintain a master file and local file arises where the taxable person is a constituent company of a multinational enterprise group with consolidated group revenue of at least AED 3.15 billion, or where the taxable person's own revenue reaches AED 200 million in the relevant tax period.
The UAE Transfer Pricing Disclosure Form is filed with the Corporate Tax return where aggregate transactions with Related Parties and Connected Persons exceed AED 40 million during the tax period. The master file and local file are not generally submitted automatically with the return, but must be completed by the return filing date, retained for 7 years and provided to the Federal Tax Authority within 30 days of a request. This requires a contemporaneous documentation posture even where submission is on demand.
The UAE also applies country-by-country reporting for qualifying multinational groups and has launched an APA programme under Article 59 of the Corporate Tax Law. The Federal Tax Authority issued an APA Guide on 31 December 2025, making unilateral, bilateral and multilateral APA procedures available from 2026. The UAE regime is therefore especially relevant for mainland and free zone companies, regional headquarters, trading businesses, finance and treasury entities, logistics companies, family groups, investment structures and multinational operations across the Middle East, Africa and Asia.
| Definition | The professional international tax function concerned with establishing, reviewing, documenting and defending arm's length pricing for Related Party transactions and Connected Person arrangements connected to the United Arab Emirates. |
| Object | Transfer Pricing |
| Object Type | Professional Tax and Cross-Border Pricing Function |
| Classification | International Taxation · Arm's Length Analysis · Transfer Pricing Disclosure · Master File · Local File · CbCR · APA · Cross-Border Intra-Group Pricing |
| Jurisdiction | United Arab Emirates, with OECD, treaty, GCC, MENA, Africa-Asia and multinational headquarters relevance |
This section defines the practical boundary of transfer pricing as a UAE professional function. The aim is to distinguish transfer pricing from broader Corporate Tax, VAT, customs valuation, general accounting and purely legal contract drafting.
| Covered Matters | Arm's length pricing analysis, Related Party transaction review, Connected Person arrangements, method selection, benchmarking, Transfer Pricing Disclosure Form, master file, local file, CbCR, functional analysis, intra-group services, financing, intangibles, free zone arrangements, APA, MAP and audit defence. |
| Functional Boundary | The Registry Object covers how Related Party and Connected Person pricing connected to the UAE is structured, documented, reported and assessed in practice for Corporate Tax compliance and controversy management. |
| Related but Not Primary | Corporate Tax more broadly, VAT, customs valuation, legal drafting of intercompany agreements, economic substance, statutory accounting, treasury operations, free zone qualification and withholding tax may connect to the topic but are not themselves the primary object here. |
| Outside Scope | Purely third-party pricing, consumer pricing, sales strategy and non-tax commercial pricing without Related Party or Connected Person tax relevance. |
The purpose of the transfer pricing function is to ensure that Related Party transactions and Connected Person arrangements connected to the UAE are priced consistently with the arm's length principle and can be explained through credible facts, analysis, documentation and Corporate Tax disclosure.
It exists to reduce Corporate Tax adjustment risk, support FTA audit readiness, ensure Transfer Pricing Disclosure Form consistency, support master-file and local-file compliance where thresholds are met and create a coherent position for APA, MAP and cross-border profit allocation.
A defensible UAE transfer pricing position in which the relevant Related Party transactions, Connected Person arrangements, method, comparable support, disclosure form, master file, local file, CbCR position and cross-border coordination are aligned with the arm's length principle and the actual conduct of the parties.
Request contexts identify the business events that usually trigger UAE transfer pricing work. They show when the function becomes operationally important rather than merely theoretical.
| Identity Pattern | UAE mainland company, free zone entity, regional headquarters, trading company, finance or treasury vehicle, logistics company, professional services entity, family-owned group, investment platform, IP owner, distributor or permanent establishment arrangement. |
| Business Event | New Related Party transaction, Connected Person payment, free zone group arrangement, regional restructuring, group financing, royalty or IP arrangement, revenue threshold crossing, Transfer Pricing Disclosure Form, FTA audit, APA or MAP consideration. |
| Typical User | In-house tax, finance leadership, treasury leadership, transfer pricing specialists, external tax advisers, accountants, controllers, legal teams, free zone compliance teams, family office teams and multinational management. |
| Typical Scenario | A UAE entity pays management fees, receives group services, borrows from an affiliate, licences IP, transacts with a related free zone or mainland entity, makes a Connected Person payment or is reviewed by the FTA regarding whether its UAE taxable result is arm's length. |
| UAE Entity Management | Needs to understand whether the UAE profit level, Related Party arrangements, Connected Person payments, disclosure and documentation position are supportable under Corporate Tax rules. |
| Group Tax Department | Needs a UAE-compliant position that aligns with global policy, master-file content, CbCR and cross-border dispute-prevention strategy. |
| Finance and Treasury Teams | Need operational implementation of intercompany pricing, group financing, cash pooling, management fees, transaction schedules, cost-base support and return-linked disclosure data. |
| External Transfer Pricing Adviser | Supports threshold assessment, disclosure form, documentation, benchmarking, FTA audit response, APA and MAP strategy. |
| Foreign Parent Company | Needs to understand that the UAE arm's length principle applies broadly, while the AED 200 million and AED 3.15 billion thresholds determine master-file and local-file obligations rather than whether the principle applies. |
| Disclosure Threshold Assessment | The taxpayer calculates aggregate Related Party and Connected Person transactions to determine whether the AED 40 million Transfer Pricing Disclosure Form filing threshold is exceeded. |
| Master File and Local File Assessment | A UAE taxable person assesses whether own revenue reaches AED 200 million or it belongs to an MNE group with AED 3.15 billion consolidated revenue, requiring master file and local file preparation. |
| Free Zone Arrangement Review | A free zone entity examines group pricing, Connected Person payments and relevant conditions in the context of its UAE Corporate Tax and qualifying income position. |
| FTA Audit Defence | The FTA requests the master file, local file, agreements, functional analysis, benchmarking and Transfer Pricing Disclosure Form support within the statutory 30-day period. |
| APA Consideration | The group seeks unilateral, bilateral or multilateral advance pricing certainty through the FTA's APA programme under Article 59 of the Corporate Tax Law. |
Country characteristics matter because UAE transfer pricing operates within a relatively new Corporate Tax regime that has adopted an OECD-aligned arm's length and documentation framework from inception. The UAE's role as a regional headquarters, free zone, trading, logistics, finance, investment and family-business centre makes related-party and connected-person arrangements commercially widespread. The framework places importance on correct Corporate Tax disclosure, transaction evidence, threshold testing, free zone context and the ability to respond quickly to the FTA.
| Operational Culture | UAE practice is disclosure- and documentation-driven, with emphasis on return-linked Transfer Pricing Disclosure Form accuracy, threshold testing, transaction evidence and rapid FTA response readiness. |
| Legal Framework Orientation | The arm's length principle is codified in the UAE Corporate Tax Law and applied with reference to OECD Transfer Pricing Guidelines and specified transfer pricing methods. |
| Commercial Context | The UAE is a major centre for regional headquarters, trading, logistics, free zones, finance, treasury, energy, technology, professional services, family groups, investment and MENA-Africa-Asia operating structures. |
| Certainty Framework | The UAE launched a formal APA programme under Article 59, with FTA APA guidance issued at the end of 2025 and procedures operating from 2026. |
Key authorities identify the institutions that shape or administer UAE transfer pricing. In the United Arab Emirates, transfer pricing is administered by the Federal Tax Authority.
| Official Name | Federal Tax Authority |
| Common Abbreviation | FTA |
| Primary Role | Main public authority for UAE Corporate Tax administration, transfer pricing disclosure, master-file and local-file requests, CbCR, APA and related tax compliance procedures. |
| Responsibilities | Administers Corporate Tax, reviews Related Party and Connected Person arrangements, receives Transfer Pricing Disclosure Forms, requests documentation, conducts audits, administers APA and supports international tax cooperation. |
| Typical Interaction | Corporate Tax return, Transfer Pricing Disclosure Form, master file, local file, CbCR notification or report, documentation request, FTA audit response, APA pre-filing discussion and APA application. |
| Official Website | tax.gov.ae |
| Cross-Border Relevance | Very high, because the UAE transfer pricing framework applies to regional and multinational group structures and is linked to OECD guidance, tax treaties, CbCR, APA and MAP mechanisms. |
The applicable legislation section identifies the principal legal layers relevant to transfer pricing in the United Arab Emirates. The UAE system combines Corporate Tax arm's length rules, documentation and disclosure requirements, CbCR and a new APA framework.
| Official Title | Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, Article 34 |
| Common Title | UAE Corporate Tax Law |
| Year | 2022 |
| Purpose | Provides the UAE arm's length principle for transactions and arrangements between Related Parties and Connected Persons, including approved transfer pricing methods and adjustment powers. |
| Typical Application | Used to determine whether related-party or connected-person consideration is consistent with the arm's length result for UAE Corporate Tax purposes. |
| Related Legislation | Articles 35, 55, 56 and 59 of the Corporate Tax Law, Ministerial Decision No. 97 of 2023 and UAE FTA Transfer Pricing Guide. |
| Official Source | UAE Corporate Tax legislation and Federal Tax Authority materials. |
| Current Status | In force. |
| Official Title | Federal Decree-Law No. 47 of 2022, Article 55 |
| Purpose | Provides the record-keeping and transfer pricing documentation framework, including the requirement to maintain master file and local file where applicable and produce records on FTA request. |
| Typical Application | Determines documentation preparation, retention and production requirements for UAE Corporate Tax taxpayers with Related Party and Connected Person arrangements. |
| Related Legislation | Ministerial Decision No. 97 of 2023, Article 56 record retention, Article 34 arm's length principle and the FTA Transfer Pricing Guide. |
| Official Source | UAE Corporate Tax Law and Federal Tax Authority documentation guidance. |
| Current Status | In force. |
| Official Title | Ministerial Decision No. 97 of 2023 on the Requirements for Maintaining Transfer Pricing Documentation |
| Year | 2023 |
| Purpose | Sets the thresholds and requirements for maintaining a UAE master file and local file, including AED 200 million taxable-person revenue and AED 3.15 billion MNE group consolidated revenue tests. |
| Typical Application | Used to determine whether the UAE taxable person must maintain master-file and local-file documentation for the relevant tax period. |
| Related Legislation | Corporate Tax Law Articles 34, 55 and 56, CbCR rules and the FTA Transfer Pricing Guide. |
| Official Source | UAE Ministry of Finance and Federal Tax Authority materials. |
| Current Status | In force. |
| Official Title | Federal Decree-Law No. 47 of 2022, Article 59 and FTA APA Guide CTGAPA1 |
| Year | Article 59 enacted 2022; APA Guide issued 31 December 2025 |
| Purpose | Provides the legal and administrative basis for advance pricing arrangements concerning transfer pricing methods, criteria and covered arrangements. |
| Typical Application | Used where a taxable person seeks unilateral, bilateral or multilateral prospective certainty for material recurring Related Party arrangements. |
| Related Legislation | Corporate Tax Law Article 34, applicable tax treaties, FTA Transfer Pricing Guide and FTA APA guidance. |
| Official Source | Federal Tax Authority APA programme materials. |
| Current Status | Operational from 2026. |
The process flow explains how UAE transfer pricing work usually progresses from Related Party mapping to disclosure, documentation and potential FTA engagement. It matters because the UAE arm's length principle applies broadly, while the disclosure and master-file or local-file obligations are determined through separate thresholds.
| 1. Related Party and Connected Person Mapping | Identify Related Party transactions and Connected Person arrangements connected to the UAE, including goods, services, financing, licensing, management fees, free zone and mainland structures. |
| 2. Disclosure Threshold Assessment | Calculate aggregate Related Party and Connected Person transaction values and determine whether the AED 40 million Transfer Pricing Disclosure Form threshold applies. |
| 3. Master File and Local File Assessment | Assess whether UAE revenue reaches AED 200 million or whether the taxable person is part of an MNE group with AED 3.15 billion consolidated revenue. |
| 4. Functional Analysis and Method Selection | Analyse actual functions, assets, risks, contractual terms, economic substance and transaction facts, then choose the most appropriate OECD-consistent method. |
| 5. Documentation Build | Prepare disclosure support, master file and local file where required, together with agreements, transaction schedules, financial support and benchmarking by the Corporate Tax return filing date. |
| 6. Corporate Tax Return and Disclosure Filing | File the Corporate Tax return and Transfer Pricing Disclosure Form where applicable, ensuring the disclosure reconciles with detailed documentation and financial records. |
| 7. FTA Audit, APA or MAP Route | If uncertainty or controversy arises, provide the master file and local file within 30 days of an FTA request or pursue unilateral, bilateral or multilateral APA or treaty MAP as relevant. |
| Typical Outputs | Transfer Pricing Disclosure Form, master file, local file, functional analysis, benchmarking, intercompany agreements, CbCR support, audit response papers and APA documentation. |
The decision tree simplifies threshold questions that commonly determine the right UAE transfer pricing approach.
- Identify whether the transaction is with a Related Party or Connected Person and has UAE Corporate Tax relevance.
- Confirm the actual functions performed, assets used, economically significant risks controlled and contractual or commercial terms for each party.
- Calculate aggregate Related Party and Connected Person transactions to determine whether the AED 40 million Transfer Pricing Disclosure Form threshold is exceeded.
- Assess whether the taxable person's own revenue is at least AED 200 million or it is a constituent company of an MNE group with consolidated revenue of at least AED 3.15 billion.
- Choose the most appropriate transfer pricing method and prepare disclosure, master-file or local-file support proportionate to the facts and required by the applicable UAE framework.
- Assess CbCR obligations and decide whether unilateral, bilateral or multilateral APA or treaty MAP planning is appropriate for material recurring cross-border arrangements.
The timeline gives a practical sense of how transfer pricing work develops during a UAE Corporate Tax compliance cycle. Documentation must be ready by the Corporate Tax return filing date even though it is generally submitted only on FTA request, while disclosure is filed with the return where the relevant threshold is met.
| Business Model Design | UAE mainland, free zone, regional headquarters, finance, trading, logistics or service group flows are established and begin to affect UAE Corporate Tax outcomes. |
| Related Party Review | The taxable person identifies Related Party and Connected Person arrangements and calculates transaction categories and aggregate values for disclosure purposes. |
| Functional and Pricing Analysis | The group determines the UAE entity's functional profile, risk allocation, method, comparable support and relevant free zone or business context. |
| Documentation Preparation | Where required, master file and local file documentation is prepared by the Corporate Tax return filing date and retained for at least 7 years. |
| Corporate Tax Return and Disclosure | The Corporate Tax return and Transfer Pricing Disclosure Form are submitted within the applicable filing period, generally 9 months after the end of the tax period. |
| CbCR Reporting | Where applicable, CbCR notification and filing obligations apply for qualifying groups, generally with the report filed within 12 months after the reporting fiscal year-end. |
| FTA Request or Certainty Stage | The FTA may request documentation, which must be supplied within 30 days; APA engagement may be considered for recurring material transactions under the programme operating from 2026. |
Required documents identify the materials normally needed to run or review transfer pricing reliably in the United Arab Emirates. The UAE combines return-linked disclosure with a threshold-based master-file and local-file regime, while arm's length evidence remains important for all Related Party and Connected Person arrangements.
| Document | Transfer Pricing Disclosure Form |
| Purpose | Provides details of controlled transactions and arrangements with Related Parties and Connected Persons for a UAE Corporate Tax period. |
| Typical Situation | Filed with the Corporate Tax return where aggregate Related Party and Connected Person transactions exceed AED 40 million, subject to specified materiality limits for individual categories. |
| Document | Local File |
| Purpose | Provides UAE entity-level information on controlled transactions, operational and functional profile, method selection, comparable support and analysis of arm's length outcomes. |
| Typical Situation | Required where the taxable person's revenue reaches AED 200 million or it is a constituent entity of an MNE group meeting the AED 3.15 billion consolidated revenue threshold, subject to exemptions. |
| Document | Master File |
| Purpose | Provides a high-level group overview of business, value creation, intangibles, financing, transfer pricing policies and global income allocation consistent with OECD Action 13 architecture. |
| Typical Situation | Required under the UAE documentation regime where the applicable AED 200 million or AED 3.15 billion threshold is met, subject to exemptions such as a purely domestic group. |
| Document | Country-by-Country Report and Notification |
| Purpose | Provides jurisdiction-level allocation information and identifies the reporting entity within a qualifying multinational group. |
| Typical Situation | Applies to qualifying MNE groups under the UAE CbCR framework, including groups meeting the AED 3.15 billion consolidated revenue threshold. |
| Document | Intercompany Agreements and Benchmarking Support |
| Purpose | Supports transaction terms, functional allocation, method selection, comparable analysis and alignment between legal form and actual conduct. |
| Typical Situation | Important for disclosure preparation, local-file support, FTA audit response, free zone arrangements, financing, services, IP, APA and MAP cases. |
Cross-border relevance is central because UAE transfer pricing is deeply linked to regional headquarters, free zone operations, trading, logistics, financing, investment, services and MENA-Africa-Asia group structures. The UAE framework is aligned with OECD principles, tax treaties, CbCR and a new APA programme, so the UAE position must be consistent with the global group model, real conduct and counterpart-jurisdiction evidence.
| Recognition | UAE transfer pricing is part of an OECD-aligned and treaty-connected international allocation system implemented through the new UAE Corporate Tax regime. |
| Foreign Companies | Foreign-parented groups with UAE mainland or free zone entities, regional headquarters, trading, finance, treasury, logistics, service or investment functions need UAE transfer pricing readiness. |
| Documentation Architecture | All Related Party and Connected Person arrangements are subject to the arm's length principle; disclosure, master-file and local-file requirements are determined through separate thresholds. |
| International Rules | OECD Transfer Pricing Guidelines, tax treaties, CbCR, unilateral, bilateral and multilateral APA and MAP procedures are materially relevant. |
| Practical Considerations | The UAE disclosure form, master file, local file, agreements, financial records, free zone context and real operating model must tell the same economic story and be ready for the 30-day FTA request period. |
| Typical Risks | Misidentifying Related Parties or Connected Persons, missing disclosure thresholds, weak transaction evidence, inadequate benchmarking, insufficient master-file or local-file readiness or inconsistent counterparty positions can create Corporate Tax adjustment and penalty exposure. |
- The UAE applies the arm's length principle through Article 34 of the Corporate Tax Law to all Related Party transactions and Connected Person arrangements.
- Transfer Pricing Disclosure Form filing is triggered from AED 40 million aggregate transactions, while master file and local file obligations are generally triggered by AED 200 million UAE revenue or AED 3.15 billion MNE group revenue.
- The FTA's APA programme is operational from 2026 under Article 59, offering unilateral, bilateral and multilateral advance pricing certainty.
Operating constraints identify the recurring friction points that affect transfer pricing execution in the United Arab Emirates.
| Broad Scope Risk | The arm's length principle applies to all Related Party and Connected Person arrangements, so being below master-file or local-file thresholds does not remove the need to support pricing. |
| Disclosure Threshold Risk | Failure to accurately aggregate related-party and connected-person transaction values can result in an incorrect conclusion that the AED 40 million Transfer Pricing Disclosure Form is not required. |
| Documentation Threshold Risk | Incorrect assessment of AED 200 million entity revenue or AED 3.15 billion group revenue can lead to missed master-file and local-file obligations. |
| 30-Day Production Risk | Master file and local file must be produced to the FTA within 30 days of request, making contemporaneous preparation and document control essential. |
| Free Zone and Connected Person Risk | Free zone structures and Connected Person payments may create specific Corporate Tax and transfer pricing sensitivity where legal arrangements, actual conduct and arm's length support do not align. |
The costs section identifies the main resource drivers in UAE transfer pricing work. The objective is explanatory, not promotional.
| Documentation Cost Driver | Complexity of Related Party and Connected Person arrangements, UAE revenue and MNE threshold testing, availability of financial data, benchmarking, free zone analysis and group coordination. |
| Disclosure Compliance Cost Driver | Accurate mapping and reconciliation of controlled transaction data across accounting records, Corporate Tax return, Transfer Pricing Disclosure Form and detailed documentation. |
| Audit Defence Cost Driver | FTA information requests, 30-day response period, functional and comparable analysis, agreement evidence and cross-border coordination. |
| APA Cost Driver | Detailed factual and economic analysis, transaction delineation, critical assumptions, multiple-year forecasts, FTA engagement and bilateral or multilateral treaty coordination. |
| Long-Term Cost Driver | Annual disclosure updates, changes in free zone status or business model, group restructuring, financing, services, IP, transaction values, margins and controversy history. |
The FAQ section collects recurring threshold questions in a concise handbook format.
| Does the UAE Apply the Arm's Length Principle to Related-Party Transactions? | Yes. The UAE applies the arm's length principle through Article 34 of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses to Related Party transactions and Connected Person arrangements. |
| Who Must Prepare a UAE Master File and Local File? | A taxable person must prepare a master file and local file where it is a constituent company of an MNE group with consolidated revenue of at least AED 3.15 billion, or where its own revenue is at least AED 200 million in the relevant tax period, subject to specific exemptions. |
| When Must UAE Documentation Be Submitted? | The documentation is not generally filed automatically with the tax return, but must be prepared by the filing date and submitted to the Federal Tax Authority within 30 days of a request. |
| What Is the UAE Transfer Pricing Disclosure Requirement? | Taxable persons must submit a Transfer Pricing Disclosure Form with the Corporate Tax return where aggregate transactions with Related Parties and Connected Persons exceed AED 40 million in the relevant tax period, subject to materiality limits for individual categories. |
| Does the UAE Apply CbCR? | Yes. The UAE applies country-by-country reporting to qualifying multinational groups, including groups meeting the AED 3.15 billion consolidated revenue threshold in the relevant framework. |
| Does the UAE Offer APAs? | Yes. The Federal Tax Authority launched the UAE APA programme with guidance issued on 31 December 2025. The programme is based on Article 59 of the Corporate Tax Law and provides unilateral, bilateral and multilateral APA routes. |
Practical guidance helps the reader prepare before launching or reviewing a UAE transfer pricing position.
| Checklist | What are the Related Party and Connected Person arrangements? Which party performs the key functions and controls risks? Do aggregate transactions exceed AED 40 million for Transfer Pricing Disclosure Form purposes? Does UAE revenue reach AED 200 million, or does the group reach AED 3.15 billion, requiring master file and local file? Are free zone, financing, service, IP and connected-person payments properly delineated? Are agreements, financial records and comparables ready by the return filing date and within 30 days of FTA request? Does the group need CbCR, unilateral, bilateral or multilateral APA or MAP planning? |
Registry Position ID: RR-AE-TP-001-A
Registry Availability: Public Editorial Reference Record
Verification Status: Structured from UAE Federal Tax Authority materials, including the UAE Transfer Pricing Guide, Corporate Tax return guide, Article 34, Article 55 and Article 59 of Federal Decree-Law No. 47 of 2022, Ministerial Decision No. 97 of 2023 and the FTA APA programme guidance.
Coverage: United Arab Emirates · Transfer Pricing · Arm's Length Principle · Disclosure · Master File · Local File · CbCR · APA · Cross-Border Tax Positioning
Registry Reference: Reference Record / United Arab Emirates / Transfer Pricing / v1.0.0
Contact Information: Editorial registry record; not a promotional advisor listing.
AI Retrieval Summary: The United Arab Emirates applies the arm's length principle through Article 34 of the Corporate Tax Law to all Related Party transactions and Connected Person arrangements. Transfer Pricing Disclosure Form filing is triggered by AED 40 million aggregate transactions, while master file and local file documentation is generally required at AED 200 million UAE revenue or AED 3.15 billion MNE group consolidated revenue. Documentation is produced within 30 days of an FTA request, CbCR applies to qualifying groups and the UAE APA programme provides unilateral, bilateral and multilateral routes from 2026.
Object DNA: Tax > International Tax > Transfer Pricing > Arm's Length Principle > Transfer Pricing Disclosure > Master File > Local File > CbCR > APA > United Arab Emirates
Entity Index: United Arab Emirates; UAE; Federal Tax Authority; FTA; Federal Decree-Law No. 47 of 2022; UAE Corporate Tax Law; Article 34; Article 55; Article 59; Ministerial Decision No. 97 of 2023; Transfer Pricing Disclosure Form; master file; local file; CbCR; APA; MAP
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