The Corporate Tax return for financial years ended 31 December 2025 is due on 30 September 2026. The transfer pricing disclosure form must be filed with it once related-party transactions exceed AED 40 million (approximately USD 10.9 million) in aggregate, or AED 4 million (approximately USD 1.1 million) in any single category among goods, services, financing and intellectual property. The two thresholds are alternative: breaching either one triggers the obligation.
What happened
For companies whose financial year follows the calendar year and therefore ended on 31 December 2025, the Corporate Tax return and the payment of the tax fall due on the same day, 30 September 2026: thirty-seven days from now. In this second filing cycle, attention shifts to what accompanies the return. The transfer pricing disclosure form, the schedule setting out transactions carried out with related parties, meaning companies and individuals within the same group, must be filed together with the return once those transactions exceed one of two thresholds. The first is AED 40 million, approximately USD 10.9 million, of aggregate related-party transactions in the financial year. The second is AED 4 million, approximately USD 1.1 million, in a single category among goods, services, financing and intellectual property. The two thresholds are alternative: breaching one is enough for the form to become mandatory.
What changes in practice
The test is no longer run on the total, it is run category by category. An intra-group loan from the UAE company to an affiliate abroad, or a royalty charged on a group trade mark, reaches AED 4 million without anyone having consciously thought they were doing transfer pricing, that is, setting the price of a transaction between parties that are not independent. On the penalty side, the regime in force since 14 April 2026 costs AED 500 per month, approximately USD 136, for the first twelve months of late filing, and AED 1,000 per month, approximately USD 272, from the thirteenth. Late payment carries 14% per annum on the unpaid tax, calculated on a monthly basis and with no upper cap.
Who it applies to
Every person registered for Corporate Tax with a financial year ended 31 December 2025, free zone entities included. The transfer pricing form is particularly relevant to UAE companies that lend to or are financed by affiliates abroad, to holding companies charging management fees to their subsidiaries, to groups licensing trade marks or software between entities under common control, and to UAE entities invoicing overseas companies that trace back to the same ultimate beneficial owner.
The exposure
The formal penalty for a missing form is not the expensive part. The expensive part is the adjustment to taxable income on audit: if the Federal Tax Authority (FTA), the UAE tax administration, takes the view that an intra-group loan has been remunerated at a rate that is not at arm's length, or that a royalty is disproportionate, it will bring the difference back into charge. And every transaction has two sides: the same adjustment can be mirrored by the tax authority of the counterparty's jurisdiction on the other group company, with the result that the same profit is taxed twice unless relief is obtained. Thirty-seven days is enough to complete a form; it is not enough to build from scratch the documentation that justifies it.
What to do now
Extract from the 2025 accounts the ledger of related-party transactions, split across the four categories: goods, services, financing, intellectual property. Total each category and test it against the AED 4 million threshold; total the whole and test it against the AED 40 million threshold. For each intra-group loan, confirm that a written agreement exists and that the rate applied can be supported by a market reference. Set an internal cut-off date ahead of 30 September, because the room to correct is needed before filing, not after.
Sources
- https://tax.gov.ae/en/taxes/corporate.tax/corporate.tax.guides.references.aspx
- https://tax.gov.ae/en/taxes/corporate.tax/news.aspx
Published 24 August 2026 on the basis of public sources and official United Arab Emirates instruments. This is not legal or tax advice. Verify your position with a qualified professional before acting.