Related-party and connected-person mapping
We identify every related party and connected person and every transaction with them, applying the FTA's 2026 clarification of who counts as a director or officer (CTP010).
Plan · Transfer pricing
Arm's length pricing, documented before anyone asks
Every price agreed with a related company must be at arm's length, the price independent parties would agree, and payments to owners and directors are deductible only at market value. We set the policy, benchmark it, draft the intercompany agreements and prepare the disclosures and files the FTA expects to see.
- Disclosure form
- AED 40m
- of related-party transactions, per the FTA's return guidance
- Master File and Local File
- AED 200m
- of revenue, or group revenue of AED 3.15bn or more
- Files on request
- 30 days
- to hand them to the FTA
- APA threshold
- AED 100m
- of controlled transactions per tax period
Plan
Who this is for
- UAE subsidiaries of foreign groups that buy from, sell to, borrow from or share costs with related companies.
- Family groups paying salaries, fees, rent or benefits to shareholders, directors, senior officers or their relatives.
- Groups whose related-party transactions exceed AED 40 million in a tax period, the level at which the FTA's return guidance asks for a disclosure form.
- Companies with revenue of AED 200 million or more, or in a group with AED 3.15 billion or more, that do not yet hold a Master File and Local File.
- Free zone entities relying on the 0% rate, where transfer pricing compliance is one of the conditions.
- Groups with large, recurring intercompany flows for which an advance pricing agreement may be worth pursuing.
What we do
The work, end to end.
Pricing policy and intercompany agreements
We set out how each type of transaction should be priced, using OECD methods, and draft or review the agreements, so the contracts, the invoices and the conduct of the parties are consistent.
Benchmarking studies
We test prices or margins against comparable independent businesses and document the arm's length range the results should fall within.
Return disclosures
We prepare the transfer pricing disclosure form and the connected-person schedule filed with the return, itemising each category above the thresholds in the FTA's return guidance.
Master File and Local File
For businesses in scope, we prepare both files in advance, so they can be handed over within the 30 days the FTA allows after a request.
Year-end adjustments
Where actual results drift from the policy, we calculate the adjustment and reflect it in the return, applying the FTA's July 2026 clarification on downward adjustments (CTP011).
Advance pricing agreements
For controlled transactions of AED 100 million or more a period, we assess whether an advance pricing agreement (APA) justifies the time and the FTA fee, and prepare the application.
How it works
Clear steps. No guesswork.
- 1
Day 1
Scoping call
At no charge, we establish which related-party flows exist and which thresholds the group is near.
- 2
Typically 1 to 2 weeks
Mapping and data
Group chart, agreements, ledgers and payments to owners and directors, shared through a secure link.
- 3
Typically 3 to 6 weeks
Analysis and benchmarking
A functional analysis of who performs which functions and bears which risks, followed by a search for comparables.
- 4
Typically 2 to 4 weeks
Documentation
Policy, agreements, return disclosures and, where in scope, the Master File and Local File.
- 5
Annually
Return and upkeep
We file the disclosures with the return and refresh the analysis as the business changes.
What you get
Deliverables
- A map of related parties, connected persons and the transactions between them
- A written transfer pricing policy using OECD methods
- Benchmarking studies with arm's length ranges
- Intercompany agreements, drafted or reviewed
- The disclosure form and connected-person schedule for the return
- A Master File and Local File, where revenue or group size requires them
- An APA feasibility note, where transactions reach AED 100 million
Know the law
The rules in brief
- 1
Transactions with related parties must be priced at arm's length, using recognised OECD transfer pricing methods.
Federal Decree-Law No. 47 of 2022, Art. 34
- 2
Payments to owners, directors, officers and their related parties are deductible only at market value and only if made wholly and exclusively for the business.
Federal Decree-Law No. 47 of 2022, Art. 36
- 3
A director is a formally appointed board member and an officer is someone with strategic decision-making authority; job titles alone do not decide it.
FTA Public Clarification CTP010
- 4
A Master File and Local File are required where revenue is AED 200 million or more, or group consolidated revenue is AED 3.15 billion or more, and must be submitted within 30 days of an FTA request.
Ministerial Decision No. 97 of 2023
- 5
The FTA's return guidance sets the disclosure form threshold at AED 40 million of related-party transactions, itemises each category above AED 4 million, excludes dividends, and asks for a schedule where payments to any one connected person exceed AED 500,000.
FTA Corporate Tax Guide on Tax Returns (November 2024)
- 6
Domestic unilateral APAs are available for controlled transactions of AED 100 million or more per tax period, cover three to five future periods with no rollback, and carry an FTA fee of AED 30,000.
FTA Corporate Tax Guide on Advance Pricing Agreements (CTGAPA1); Cabinet Decision No. 174 of 2025
The arm's length rule applies to every business with related-party transactions, whatever its size, including businesses that elect Small Business Relief. What changes with size is the documentation. The FTA's return guidance sets the disclosure form threshold at AED 40 million of related-party transactions, and a Master File and Local File are required only from AED 200 million of revenue or AED 3.15 billion of group revenue.
Connected persons are a company's owners, directors and officers, and their related parties. Payments to them, such as salaries, fees or rent, are deductible only at market value and only if made wholly and exclusively for the business. Under the FTA's April 2026 clarification, a director is a formally appointed board member and an officer is someone with strategic decision-making authority, whatever their title. The FTA's return guidance asks for a schedule where payments or benefits to any one connected person exceed AED 500,000.
It is a schedule filed with the corporate tax return that summarises related-party transactions. The FTA's return guidance requires it where these total more than AED 40 million in the tax period, with each category above AED 4 million itemised: goods, services, intellectual property, interest, assets, liabilities and other transactions. Dividends are left out.
A business with revenue of AED 200 million or more in the tax period, or one belonging to a multinational group with consolidated revenue of AED 3.15 billion or more. The files are not filed with the return, but they must be handed over within 30 days of an FTA request. That is not long enough to prepare them from scratch, so they should exist before a request arrives.
An advance pricing agreement fixes with the FTA how specific related-party transactions will be priced for three to five future tax periods. The FTA has accepted domestic unilateral APAs since December 2025, for controlled transactions of AED 100 million or more a period, with a fee of AED 30,000 for a new application and AED 15,000 for a renewal or amendment. Cross-border APAs were promised for 2026, but no launch had been announced by early October 2026. An APA brings certainty but requires time and full disclosure, so it suits large, stable, recurring flows.
In some cases, yes. Where a related-party price turns out to be above or below arm's length, the adjustment can go either way. The FTA issued Public Clarification CTP011 in July 2026 on downward adjustments in returns, and we apply it when preparing the computation.
Because compliance with the transfer pricing rules is one of the conditions for the 0% rate as a Qualifying Free Zone Person (QFZP). Failing it costs QFZP status for that tax period and the next four. We document free zone entities' related-party dealings to the same standard as any other business.
Often needed together
Talk to us
Which thresholds has the group crossed?
Send us the group chart and last year's related-party totals. We will set out which disclosures and files apply and where the gaps are. The first conversation is free.
- FTA Registered Tax Agency
- Tax team with Big Four audit-firm experience
- Mon to Fri, 9:00 am to 6:00 pm (GST)
Request a call back