On 22 October 2025, the OECD released a new set of updated Transfer Pricing Country Profiles, reflecting the current transfer pricing (TP) legislation and practices. For the first time, the update includes profiles for Cabo Verde, Guatemala, Thailand, the United Arab Emirates (UAE), and Zambia.
The newly published UAE Transfer Pricing Country Profile outlines the applicable transfer pricing documentation requirements.
A Local File and Master File are required if either:
the consolidated group revenue for the tax period reaches AED 3.15 billion, or
the taxpayer’s revenue for the tax period amounts to AED 200 million or more.
Even where there is no formal obligation to maintain transfer pricing documentation, the Federal Tax Authority (FTA) retains the right to request supporting justification.
Documentation may be prepared in English and/or Arabic.
Although the UAE generally aligns its transfer pricing framework with OECD guidelines, several distinctions remain:
The UAE has not yet adopted a formal position on Amount B, but it has confirmed its political commitment to Amount B (further details are available on our portal).
UAE legislation does not provide specific guidance on the treatment of hard-to-value intangibles (HTVI). In practice, taxpayers are expected to rely on OECD principles in this area.
Businesses applying the Small Business Relief regime are exempt from transfer pricing documentation requirements.
The UAE’s extensive network of double tax treaties does not always follow the OECD Model Convention; some treaties are based on the UN Model Tax Convention.
In addition, Cabinet Decision No. 2 of 2025 deserves special attention, as it provides clarification on the framework for concluding Advance Pricing Agreements (APAs). A detailed analysis is available in our dedicated publication.
Overall, these developments demonstrate that the UAE continues to strengthen cooperation with international organizations such as the OECD, while reinforcing its position as a leading global financial hub committed to transparency, sound governance, and international tax compliance.
