UAE Corporate Tax Fundamentals/Transfer Pricing (Art. 34)
10 min

Arm Length Principle

Arm length principle for related-party transactions and the de minimis threshold.

Transfer Pricing (Article 34)

The Arm Length Principle

Related-party transactions must be priced at arm length — the price that independent parties would agree to in comparable circumstances.

Who Are Related Parties?

Two persons are related if:

  • One controls the other (50%+ ownership or voting rights)
  • Both are controlled by the same person
  • They are connected through family relationships

De Minimis Threshold

Transfer pricing rules apply if the aggregate value of related-party transactions exceeds AED 15 million per tax period (for medium-sized entities) or AED 40 million (for large entities).

Accepted Methods

  1. CUP (Comparable Uncontrolled Price) — compare prices of similar transactions
  2. Resale Price Method — based on gross margin
  3. Cost Plus Method — based on cost plus mark-up
  4. Transactional Net Margin Method (TNMM) — based on net profit margin
  5. Profit Split Method — based on profit division

Documentation

For transactions above the threshold:

  • Maintain a transfer pricing study
  • Prepare a master file and local file (for large entities)
  • Keep supporting data for the selected method

FTA Audit

The FTA may adjust profits if transactions are not at arm length. Penalties apply for non-compliance.

Key takeaways

  • Related-party transactions must be at arm length
  • De minimis threshold is AED 15M (medium) or AED 40M (large)
  • Five accepted methods are available
Knowledge check

1. What is the arm length principle?

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This lesson is general educational content, not individualized tax or legal advice. Always consult a qualified professional for your specific situation.