18 August 2026 · Compare
Unilateral vs Bilateral APA in the UAE
A unilateral APA involves only you and the FTA and covers related-party dealings inside the UAE; it has been available since 30 December 2025. A bilateral or multilateral (cross-border) APA also brings in a foreign tax authority, which removes double-taxation risk on international related-party transactions, and is expected to open during 2026. The choice follows your structure: a UAE-only group with domestic intercompany charges can use the unilateral track now, while a group with a foreign parent or subsidiary may need the cross-border route.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
You and the FTA
The domestic track, open now.
- Involves only you and the FTA.
- Covers domestic controlled transactions.
- Available since 30 December 2025.
- Fastest route to certainty inside the UAE.
Adds a foreign authority
For international flows.
- Bilateral or multilateral.
- Brings in a foreign tax authority.
- Removes double-taxation risk.
- Expected to open during 2026.
It follows structure
Match the track to the group.
- UAE-only group: unilateral now.
- Foreign parent or subsidiary: cross-border.
- Consider where the risk sits.
- Some groups will use both over time.
Related guides
Frequently Asked Questions
For choosing a track.
What is a unilateral APA?
An agreement involving only your business and the FTA, covering domestic controlled transactions inside the UAE. It has been available since 30 December 2025.
What is a cross-border APA?
A bilateral or multilateral APA that also involves a foreign tax authority, used to remove double-taxation risk on international related-party transactions. It is expected to open during 2026.
Which one should we use?
It depends on your structure. A UAE-only group with domestic intercompany charges can use the unilateral track now; a group with a foreign parent or subsidiary may need the cross-border route.
Can I start unilateral and add cross-border later?
Many groups will. The unilateral track gives domestic certainty now, and a cross-border APA can address international flows when that programme is available.
Does cross-border take longer?
Typically yes, because it requires agreement between two tax authorities as well as you. The trade-off is that it also removes double-taxation risk that a unilateral APA cannot.
Can Exiloz advise on the right track?
Yes. We assess your structure and related-party flows and recommend the unilateral or cross-border route.
Pick the right track
Exiloz recommends the unilateral or cross-border APA route for your structure.