The UAE's Second TP Filing Season: Navigating New Clarifications and Compliance Expectations
The Federal Tax Authority ("FTA") has recently issued a series of public clarifications addressing several practical Transfer Pricing ("TP") issues that emerged during the initial years of the UAE Corporate Tax regime. These clarifications reflect the FTA's continued efforts to enhance certainty, reduce interpretational ambiguities, and foster a more transparent and collaborative relationship with taxpayers. There are no major changes in the regulations from a Transfer Pricing perspective, and the legislative architecture continues to be anchored in Articles 34 to 36 of the Corporate Tax Law (including Article 55 for the documentation requirements), supported by Cabinet Decision No. 100 of 2023, Ministerial Decision No. 97 of 2023, and the UAE Transfer Pricing Guidelines. The arm's length principle remains the cornerstone of the regime, and the UAE continues to closely align its TP framework with internationally accepted OECD principles.
