20 August 2026 · Disclosure
The UAE Transfer Pricing Disclosure Form
The transfer pricing disclosure form is submitted together with your corporate tax return on EmaraTax wherever your related-party and connected-person transactions exceed the reporting thresholds — thresholds that sit well below the AED 200 million Master File trigger, so many businesses that never need a full Master and Local File still have to complete this form. It summarises the nature and value of those transactions, the relationships involved, and the transfer pricing method used for each, so the FTA can see your intra-group activity at a glance even if it never requests your full documentation. Because it is filed every year, it is also the field the FTA checks first for consistency against your accounts.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
A summary the FTA sees every year
Unlike the Master and Local File, the disclosure form is filed with the return every year, not held in reserve and produced only on request. It is completed on EmaraTax at the same time as the corporate tax return, so there is no separate deadline to track once the return itself is due. Because it is filed annually rather than reviewed only occasionally, small errors compound — a mismatch repeated across several years is a bigger flag than one appearing in a single filing.
- Submitted alongside the corporate tax return on EmaraTax.
- Reports related-party transactions above the threshold.
- Reports payments to connected persons.
- States the transfer pricing method applied to each.
- Filed every year the thresholds are met, not once.
- No separate deadline — it moves with the CT return date.
Consistency is everything
The form is effectively a map the FTA uses to decide who to look at more closely, and mismatches are what draw that attention. Figures need to tie back to your financial statements to the dirham, the methods you declare need to match what your benchmarking study and Local File actually say, and connected-person payments need to reflect the arm's length limits you can evidence elsewhere. A disclosure form completed in isolation from the rest of your transfer pricing file is one of the more common reasons a routine filing turns into a wider review.
- Figures must reconcile to your financial statements.
- Methods must match your benchmarking and Local File.
- Connected-person payments must reflect arm's length limits.
- Errors here are a common audit trigger.
- Should be completed after, not before, the underlying analysis.
- A repeated mismatch across years is a stronger flag than one.
What information the form actually asks for
The form is built around categories rather than free text: the nature of each related-party or connected-person transaction, the counterparty and its relationship to you, the value involved, and the method used to price it. It is designed to be filled in from an existing transfer pricing analysis, not to generate one — trying to complete it without a functional analysis and benchmarking behind it usually means guessing at the method field. Getting the categorisation right the first time also makes next year's filing faster, since the underlying transactions rarely change completely from one year to the next.
- Nature, counterparty and relationship for each transaction.
- Transaction value, matched to your accounts.
- The pricing method used, matched to your Local File.
- Best completed from an existing analysis, not from scratch.
Common disclosure form mistakes
The most frequent issue is not fraud, it is disconnection — the form gets completed by whoever files the CT return, separately from whoever built the benchmarking study, and the two documents drift apart. Rounding differences against the financial statements, connected-person payments left off because they were not thought of as “transfer pricing”, and a method box filled in from memory rather than from the actual Local File are the three we see most. Reviewing the prior year's form before completing the next one catches most of these before they repeat.
- Form completed separately from the benchmarking and Local File.
- Connected-person payments omitted because they seemed unrelated.
- Method declared from memory rather than the actual documentation.
- Prior-year filings never reviewed before the next one is submitted.
Related guides
Frequently Asked Questions
For anyone completing the corporate tax return and working out what the disclosure form actually requires.
Is the disclosure form the same as the Local File?
No. The disclosure form is a short summary filed with the return every year; the Local File is the detailed documentation behind it, held internally and produced only if the FTA asks for it within its 30-day window.
Who has to complete it?
Businesses whose related-party and connected-person transactions exceed the reporting thresholds set for the form — thresholds that are lower and broader than the AED 200 million Master File trigger, so more businesses are in scope for this than for full documentation.
What are connected persons?
Owners, directors and officers of the business, and their relatives, plus related parties of those people. Payments to them must be arm's length, and the form is one of the places that gets reported every year.
Do I need to file if I have no related-party transactions?
If your transactions genuinely fall below the reporting thresholds, the specific disclosure obligation does not arise for that year — but this should be confirmed each year, since a new related-party arrangement or a connected-person payment can bring you into scope.
What happens if the disclosure form contains errors?
An error that surfaces on review can trigger a wider look at your related-party dealings, and depending on the nature of the mistake, may carry administrative penalties in addition to any underlying transfer pricing adjustment. Reconciling the form to your accounts before filing is the main safeguard.
Is the disclosure form made public?
No. It is filed with the FTA through EmaraTax as part of your corporate tax return and is not published or shared with counterparties — it is a compliance document, not a disclosure to the market.
Can the disclosure form be amended after filing?
Corrections generally follow the same voluntary disclosure route available for other errors on a filed corporate tax return — the earlier a mistake is caught and corrected, the smaller the exposure tends to be.
Can Exiloz complete the disclosure form for us?
Yes. We prepare the form directly from your benchmarking study and Local File so it reconciles to your accounts and matches your documentation, and we review the prior year's filing first to catch anything that needs correcting.
File a clean disclosure form
Exiloz completes your transfer pricing disclosure form from the same analysis behind your Local File, so the numbers tie out and nothing invites a second look.
