18 August 2026 · Definition
What Is a UAE Advance Pricing Agreement?
An advance pricing agreement is a written agreement between your business and the FTA that fixes the transfer-pricing method for specified related-party transactions over a fixed future period. It does not fix a single price; it fixes the method and the assumptions behind it, so as your numbers change the agreed method still gives an arm's-length answer. The value is certainty: for the covered transactions and years, the FTA will not re-price them, provided you apply the method and the assumptions hold.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
A method, agreed up front
Not a price, a method.
- Written agreement with the FTA.
- Covers specified related-party transactions.
- Fixes the transfer-pricing method.
- Runs for a fixed future period.
It removes uncertainty
The audit argument moves forward.
- Arm's-length pricing is required by Article 34.
- Wrong pricing risks audit adjustments.
- An APA agrees the method in advance.
- Covered years are protected from re-pricing.
It is not automatic
You must hold the line.
- Apply the agreed method consistently.
- Keep to the critical assumptions.
- File the compliance the APA requires.
- Breach either and protection can fall away.
Related guides
Frequently Asked Questions
For groups new to APAs.
What does an APA fix?
It fixes the transfer-pricing method and the critical assumptions for specified related-party transactions, not a single price. As your figures move, the agreed method still produces an arm's-length result.
Who agrees an APA?
You and the FTA, for a unilateral APA. A cross-border APA also involves a foreign tax authority. The agreement is written and covers a fixed future period.
What is the benefit?
Certainty. For the covered transactions and years, the FTA will not come back and re-price them, provided you apply the agreed method and the assumptions hold.
Is an APA permanent?
No. It runs for a fixed period and holds only while you apply the method and the critical assumptions keep holding. It can be renewed.
Which law underpins it?
The arm's-length principle in Article 34 of Federal Decree-Law No. 47 of 2022, with the programme set out in the FTA's APA guide published in December 2025.
Can Exiloz assess if we need one?
Yes. We review your related-party transactions and advise whether an APA is worth pursuing for your group.
Understand the instrument
Exiloz explains whether an APA fits your related-party transactions.