The Ultimate Guide to UAE Corporate Tax and Transfer Pricing

UAE Corporate tax

The introduction of corporate tax in the UAE has marked a transformative moment in the country’s economic and regulatory landscape. For decades, the UAE was known for its tax-free business environment, but beginning from June 1, 2023, the Federal Tax Authority (FTA) introduced a 9% corporate tax on business profits exceeding AED 375,000. While this move aligns the UAE with international standards and enhances transparency, it also brings with it a host of obligations for businesses operating locally and globally. This guide helps you navigate the maze of UAE tax law, including local corporate tax, transfer pricing, documentation, and international considerations. 

Let’s walk through each major area of corporate tax and transfer pricing, linking to in-depth articles for each topic. 

 

What is UAE Corporate Tax? Applicability, Exemptions, and Rates Explained

To begin understanding the UAE tax regime, businesses need to grasp who is subject to tax and what qualifies as taxable income. While the 9% tax rate applies to most business entities with profits above AED 375,000, exemptions exist for certain sectors, such as government entities, extractive businesses, and qualifying public benefit entities. In this cluster article, we explore how the tax applies to onshore and free zone businesses, the treatment of foreign source income, and the basics of taxable accounting. 

Read more: What is UAE Corporate Tax? Applicability, Exemptions, and Rates Explained 

 

How to Register and File Corporate Tax in the UAE

Compliance begins with proper registration and timely filings. Every business subject to corporate tax must register with the FTA and maintain relevant records for at least seven years. This section outlines the step-by-step registration process, how to file returns, maintain documentation, and avoid administrative penalties. It also highlights who qualifies for the Small Business Relief regime and how to elect it. 

Read more: How to Register and File Corporate Tax in the UAE 

 

Are Free Zone Companies Subject to UAE Corporate Tax?

The tax treatment of free zone companies remains one of the most discussed aspects of the UAE tax regime. While free zones were traditionally tax-exempt, the new regime introduces the concept of “Qualifying Free Zone Persons,” whose income from specific activities and geographies may still enjoy a 0% rate. We explore the rules, the qualifying income conditions, and compliance requirements that these businesses must meet to retain their preferential status. 

Read more: Are Free Zone Companies Subject to UAE Corporate Tax? 

 

UAE Transfer Pricing Rules: Are You Compliant?

Transfer pricing is not just for multinationals anymore. Under the new tax law, any business engaging in transactions with related parties or connected persons must ensure that these transactions follow the arm’s length principle. This section introduces the concept of transfer pricing, its basis in OECD guidelines, and the mandatory compliance rules under UAE tax law. Even SME groups must now evaluate whether they meet the documentation thresholds. 

Read more: UAE Transfer Pricing Rules: Are You Compliant? 

 

Master File and Local File: What UAE Businesses Need to Know

Transfer pricing documentation has become a critical compliance issue. Businesses crossing the AED 200 million consolidated group revenue threshold must prepare both a Master File and a Local File. This section explains what these files should contain, who needs to prepare them, and the submission timelines. It also outlines the importance of functional analysis and benchmarking studies. 

Read more: Master File and Local File: What UAE Businesses Need to Know 

 

UAE CbCR Rules for Multinational Groups

Country-by-Country Reporting (CbCR) is another layer of international tax compliance required for multinational groups with consolidated revenues exceeding AED 3.15 billion. Even if the reporting obligation lies with a foreign parent, UAE subsidiaries may have a notification obligation. This cluster explores the filing process, timelines, and penalties for non-compliance with CbCR rules. 

Read more: UAE CbCR Rules for Multinational Groups 

 

Tax Residency and ESR Compliance in the UAE

With the introduction of corporate tax, the distinction between tax residency and Economic Substance Regulations (ESR) becomes more critical. Companies must determine whether they are tax residents in the UAE and comply with ESR if they engage in relevant activities such as holding, distribution, finance, or IP. This section clarifies how ESR and corporate tax intersect, and how your business can maintain good standing. 

Read more: Tax Residency and ESR Compliance in the UAE 

 

Top 10 Mistakes UAE Businesses Make in Corporate Tax Filings

Even well-managed companies can misstep when adjusting to new tax regulations. From misclassifying free zone income to missing deadlines, common pitfalls can lead to penalties, audits, and reputational damage. In this section, we outline the most frequent mistakes we see clients make, and how to avoid them with proper planning, documentation, and professional guidance. 

Read more: Top 10 Mistakes UAE Businesses Make in Corporate Tax Filings 

 

Fines, Audits, and Enforcement: UAE Corporate Tax Penalties Explained

The Federal Tax Authority has a defined structure of administrative penalties for non-compliance with the UAE corporate tax law. This cluster covers what triggers a tax audit, the most common infractions, and the magnitude of fines associated with each. Learn how to prepare for potential audits and manage disputes with the tax authority professionally and efficiently. 

Read more: Fines, Audits, and Enforcement: UAE Corporate Tax Penalties Explained 

 

Why You Need Legal Counsel for UAE Tax Compliance

The complexity of UAE tax law—especially with respect to transfer pricing, free zone benefits, and cross-border income—requires more than just accounting support. Legal counsel plays a pivotal role in structuring, compliance, risk mitigation, and responding to audits or enforcement actions. This article explains why partnering with a corporate legal advisor helps businesses stay compliant while optimizing tax outcomes. 

Read more: Why You Need Legal Counsel for UAE Tax Compliance 

 

How to Legally Minimize Corporate Tax in the UAE

Tax planning is not tax evasion. Within the scope of law, businesses can strategically structure their operations to reduce tax burdens. Whether it’s through group structuring, IP management, intra-group pricing strategies, or incentive utilization, this section provides a look at smart, ethical ways to plan ahead. 

Read more: How to Legally Minimize Corporate Tax in the UAE 

 

Doing Business Across Borders: UAE Tax Implications for International Companies

Cross-border operations require careful consideration of permanent establishment rules, double tax treaties, withholding tax concerns, and transfer pricing. This article offers insights into how the UAE’s tax rules apply to international companies doing business in or through the UAE, and how to stay compliant globally. 

Read more: Doing Business Across Borders: UAE Tax Implications for International Companies 

 

VAT and Corporate Tax: What UAE Businesses Must Know About Both

Now that the UAE imposes both Value Added Tax (VAT) and Corporate Tax, businesses must understand how these two regimes differ and interact. This section compares the applicability, rates, documentation, and compliance procedures for both taxes, helping companies manage both sets of obligations effectively. 

Read more: VAT and Corporate Tax: What UAE Businesses Must Know About Both 

 

Taxation of Holding Companies in the UAE: Opportunities and Risks

Holding companies have unique tax considerations, particularly around dividend income, capital gains, and foreign subsidiaries. With the right setup, these companies can act as efficient vehicles for regional or global investment. This article explores the pros and cons of using UAE holding companies under the corporate tax regime. 

Read more: Taxation of Holding Companies in the UAE: Opportunities and Risks 

 

How UAE Corporate Tax Affects Family Offices and Privately Held Companies

Family-owned businesses and private companies form the backbone of the UAE’s economy. Corporate tax may impact long-standing legacy structures, intergenerational transfers, and asset ownership planning. This article explores how family offices and closely held entities can stay compliant while preserving wealth and control. 

Read more: How UAE Corporate Tax Affects Family Offices and Privately Held Companies 

 

How is E-Commerce and Tech Business Income Taxed in the UAE?

Digital businesses face unique challenges under corporate tax regimes due to the intangibility of products and services. This article addresses how e-commerce and tech companies operating in the UAE can determine taxable income, the risks of creating permanent establishments, and how IP and digital services are treated under UAE law. 

Read more: How is E-Commerce and Tech Business Income Taxed in the UAE? 

 

Pricing Intra-Group Services in the UAE: Transfer Pricing Best Practices

Intra-group services such as management support, administrative coordination, and back-office functions must be priced at arm’s length. The UAE’s transfer pricing rules require justification of service charges with proper documentation. This cluster explains cost allocation methods, the importance of comparables, and what auditors typically scrutinize. 

Read more: Pricing Intra-Group Services in the UAE: Transfer Pricing Best Practices 

 

How to Handle Tangible vs Intangible Transactions in UAE Transfer Pricing

Transactions involving tangible goods and intangible assets (such as brands, software, or goodwill) require different pricing methodologies. This section outlines best practices, relevant OECD guidelines, and UAE-specific considerations for handling these types of transactions compliantly. 

Read more: How to Handle Tangible vs Intangible Transactions in UAE Transfer Pricing 

 

Intragroup Loans and Guarantees: What UAE Transfer Pricing Rules Say

Financial transactions within a group—including loans, guarantees, and cash pooling—are under increased scrutiny. This article explains the transfer pricing expectations, thin capitalization norms, and documentation requirements businesses should follow for related-party financing arrangements. 

Read more: Intragroup Loans and Guarantees: What UAE Transfer Pricing Rules Say 

 

Voluntary Disclosures, Clarifications, and Dealing with the FTA

Mistakes happen, but the FTA provides structured ways to rectify them. This final cluster explains how to submit voluntary disclosures, seek clarifications from the authority, and prepare for investigations or enforcement actions. A proactive approach can go a long way in avoiding penalties and preserving reputation. 

Read more: Voluntary Disclosures, Clarifications, and Dealing with the FTA 

 

Stay tuned for ongoing updates to this guide as UAE tax regulations evolve. Explore our in-depth cluster articles linked above or get in touch with our advisory team for tailored support. 

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Ajay is an experienced accounting professional known for his precision and client-focused approach. He brings deep expertise in bookkeeping, financial reporting, and business advisory services, ensuring clients meet their financial goals.

Abhijith brings over four years of experience from a chartered accountancy firm, where he built a strong foundation in statutory compliance, audits, accounting, finance, and taxation. His academic background in finance seamlessly complements his professional journey.