The UAE Corporate Tax Return contains a specific schedule for disclosing related party transactions — the Transfer Pricing (TP) Disclosure Form. Many businesses with group structures, intercompany loans, management fees, or shared services arrangements will need to complete this schedule.
But not every company with related party transactions is required to file it. The obligation is triggered by specific monetary thresholds, and the rules on what to disclose once those thresholds are crossed are equally precise. This guide explains the full picture — including the dividend exclusion that catches many preparers off guard.
What Is the TP Disclosure Form?
The Related Party Transaction Schedule — commonly referred to as the TP Disclosure Form — is a schedule within the UAE Corporate Tax Return. Its purpose is to disclose high-value transactions with Related Parties as defined under Article 35 of the Corporate Tax Law.
This is distinct from broader transfer pricing documentation such as a Local File or Master File. The TP Disclosure Form is a compliance-level disclosure within the CT Return itself, not a standalone document. It gives the Federal Tax Authority visibility over significant intercompany transactions without requiring full TP documentation to be submitted upfront.
The TP Disclosure Form requirement derives from Article 35 of Federal Decree-Law No. 47 of 2022 (the UAE Corporate Tax Law) and is detailed in the UAE CT Return Guide at page 117.
Who Must Complete the TP Disclosure Form?
The obligation to complete the TP Disclosure Form applies to all Taxable Persons who meet a two-stage threshold test during the Tax Period:
Both thresholds work together: Stage 1 determines whether the schedule must be completed at all; Stage 2 determines which specific transaction categories appear within it.
The Two-Stage Test: How It Works in Practice
The Dividend Exclusion — A Critical Detail
One of the most commonly overlooked aspects of the TP Disclosure Form is the explicit carve-out for dividends:
Dividends declared between Related Parties do not need to be disclosed in the TP Disclosure Form and should not be taken into account when calculating either the AED 40 million aggregate threshold or the AED 4 million per-category threshold.
This is significant for group structures where dividend flows between entities are substantial. A company that distributes AED 50 million in dividends to a Related Party parent company does not automatically trigger the TP Disclosure Form solely on account of those dividends. The AED 40 million test is applied to the remaining related party transactions after dividends are stripped out.
When calculating whether a client has exceeded the AED 40 million threshold, always prepare a schedule of related party transactions before applying the dividend exclusion, then remove dividends to arrive at the correct comparison figure. This avoids both under-inclusion (triggering the form when not required) and over-inclusion (missing the obligation because dividends were incorrectly netted in).
How to Report: Gross Figures, Per Party, Per Category
The CT Return Guide sets out specific rules on how figures must be presented in the TP Disclosure Form. These are not optional — they reflect the FTA's requirements for the schedule:
TP Disclosure Form vs. Transfer Pricing Documentation
It is important not to confuse the TP Disclosure Form with the broader transfer pricing documentation framework. They serve different purposes and carry different obligations:
- Schedule within the CT Return
- Triggered at AED 40M aggregate related party transactions
- Discloses transaction types and amounts per party
- Submitted annually with the CT Return
- Does not require pricing methodology explanation
- Standalone TP documentation
- Different (higher) thresholds apply
- Includes arm's length analysis and benchmarking
- Not submitted with CT Return — held on file
- Produced upon FTA request or as required
A company may be required to complete the TP Disclosure Form without being required to prepare a full Local File — and vice versa depending on threshold levels and entity size. Both obligations should be assessed independently for each Tax Period.
Failure to complete the TP Disclosure Form when required, or completing it inaccurately, exposes the Taxable Person to administrative penalties under the UAE CT Law. The FTA has the authority to request supporting documentation and to adjust related party transaction values where arm's length pricing cannot be demonstrated.
Compliance Checklist: TP Disclosure Form
- Identify all Related Parties as defined under Article 35 of the CT Law — includes connected persons, group companies, and individuals with significant influence
- Compile all related party transactions for the Tax Period from the Financial Statements — exclude dividends before applying the AED 40M test
- Test the AED 40 million threshold — if total related party transactions (ex-dividends) are below AED 40M, no TP Disclosure Form is required
- Apply the AED 4 million per-category filter — only disclose transaction categories where aggregate amounts per category exceed AED 4M
- Report gross income and expenditure separately — do not net off revenue against cost for the same Related Party
- Break down figures per Related Party and per transaction type — not as combined totals
- Ensure CT registration is complete before filing — the CT Return cannot be submitted without a valid TRN
Fastlane provides end-to-end Corporate Tax return preparation for UAE businesses, including the TP Disclosure Form schedule, qualifying income analysis, and FTA submissions. Services include CT registration from AED 199, CT filing, and CT deregistration from AED 399.
Frequently Asked Questions
Reviewed by Fastlane Tax Team
This article has been reviewed by Fastlane Management Consultancy's UAE Corporate Tax team. Fastlane is registered with the UAE Ministry of Economy and the Federal Tax Authority (TRN: 104218042400003), providing CT registration, filing, and TP advisory services to businesses across Dubai and the UAE.