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16 July 2026
Navigating Transfer Pricing Adjustments: Key Insights from the FTA's Latest Clarification  
The UAE Federal Tax Authority (FTA) has issued Corporate Tax Public Clarification (CTP011), providing important guidance on the treatment of downward transfer pricing adjustments made by taxpayers in their Corporate Tax Returns. The clarification reinforces the application of the arm's length principle to related party transactions and outlines the compliance and disclosure expectations where transfer pricing adjustments are made.

Important Considerations

  1. Arm's Length compliance remains an important aspect

All transactions and arrangements with related parties must comply with the arm's length principle. Where financial statements do not reflect arm's length pricing, taxpayers are required to make appropriate transfer pricing adjustments in their Corporate Tax Returns to align taxable income with arm's length outcomes.

Such an adjustment may be either an upward adjustment or a downward adjustment, depending on whether the recorded transaction value is below or above the arm's length price.

  2. The self-assessment approach applies

Taxpayers are responsible for self-assessing whether transfer pricing adjustments are required and may make such adjustments without obtaining prior approval from the FTA. However, these adjustments remain subject to review as part of a tax audit.

Earlier, as per the UAE transfer pricing framework, taxpayers were generally required to seek FTA approval to obtain relief through a downward adjustment.

  3. Enhanced disclosure requirement for downward adjustments

A notable aspect of the clarification is that all Related Party transactions for which a downward adjustment is made must be disclosed in the Corporate Tax Return, irrespective of the transaction value, nature, or applicable reporting thresholds. This is a stricter disclosure requirement than that generally applicable to Related Party transactions, and the FTA portal has already been updated accordingly to include disclosure requirements for transactions involving downward adjustment.

  4. Robust documentation is essential 

Taxpayers making downward adjustments should maintain adequate supporting documentation, including:
  • Commercial rationale explaining why the original pricing was not at arm's length;
  • Arm's length analysis supported by benchmarking studies;
  • Reconciliation between financial statement values and tax return values; and
  • Evidence of corresponding adjustments by relevant related parties, where applicable.
Notably, an important distinction made by the FTA is that this clarification applies only to adjustments required under Article 34(1) of the Corporate Tax Law, which governs compliance with the arm's length principle. The clarification does not address corresponding adjustments available under:
  • Article 34(10), where the FTA makes a corresponding adjustment for a related party following an arm's length correction; or
  • Article 34(11), where a foreign tax authority has made an adjustment and a UAE taxpayer seeks a corresponding adjustment from the FTA.
Taxpayers should therefore avoid conflating self-initiated downward adjustments with formal corresponding adjustment mechanisms.
Our Comments

The clarification places an increased emphasis on taxpayer accountability in ensuring that Related Party transactions comply with the arm's length principle. While taxpayers now have the flexibility to self-assess and rectify the transfer pricing outcomes through downward adjustments, and the FTA expects such positions to be supported by comprehensive documentation and appropriate disclosures in the CT return.

Additionally, taxpayers can no longer assume that immaterial related party transactions fall outside reporting obligations if those transactions give rise to downward adjustments. Even relatively small transactions may require disclosure if they affect taxable income through a downward transfer pricing correction.

Taxpayers with intercompany transactions should proactively review their transfer pricing arrangements, assess whether any adjustments are required prior to filing their Corporate Tax Returns, and ensure that sufficient contemporaneous documentation is maintained to support their tax positions and withstand potential scrutiny during an FTA tax audit, along with analyzing the disclosure requirements.
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