Transfer Pricing Disclosure Form (TPDF) Filing

The TPDF (Transfer Pricing Disclosure Form), formally the Related Party Transactions disclosure schedule, is filed with every Corporate Tax return on EmaraTax once related-party or Connected Person transaction values cross the disclosure threshold under Ministerial Decision No. 97 of 2023. It summarises transactions by category and counterparty. A Local File is a much more detailed, entity-specific document — business description, FAR analysis, method selection, benchmarking — required only once higher revenue thresholds are met, and produced to the FTA on request rather than filed with the return.

Any UAE taxable person with related-party transactions or Connected Person payments that cross the disclosure threshold prescribed under Ministerial Decision No. 97 of 2023, for the relevant tax period — regardless of whether the taxable person also meets the separate, higher thresholds for Local File or Master File preparation. This threshold is materially lower and catches far more UAE businesses than the documentation thresholds.

Yes, if those entities are related parties under Article 35 — which turns on ownership and control thresholds, not on whether a border was crossed. Two mainland companies, or a mainland entity and its own Free Zone affiliate, under common family control are related parties for Corporate Tax purposes, and their intercompany dealings are disclosable once they cross the threshold, exactly as a cross-border related-party transaction would be.

Yes, if it qualifies as a Connected Person payment under Article 36 and crosses the applicable disclosure threshold. Owners, directors, officers and their relatives are Connected Persons, and payments to them — salary, benefits-in-kind, rent on premises they personally own, interest on loans they have advanced to the company — belong on the disclosure schedule, separate from ordinary third-party payroll.

Broadly: sale and purchase of goods with related parties, provision or receipt of services, royalties and licence fees, intercompany financing (loans, guarantees, interest), other intercompany arrangements such as cost-sharing, and Connected Person payments captured separately under Article 36. The exact categorisation and required detail follow the EmaraTax Corporate Tax return workflow and current FTA guidance.

Yes. Every figure on the TPDF should trace back to the audited or management financial statements for the same period. A mismatch — whether from netting intercompany balances differently, using a different exchange rate, or simply an unreconciled figure — is one of the most common triggers for an FTA follow-up query, even where the underlying transaction was entirely legitimate.

Not automatically — the two should be consistent, but the disclosure form is populated and filed separately with the Corporate Tax return, and it is the taxable person's responsibility to ensure the figures match. PNPC cross-checks the disclosure schedule against the Local File's transaction detail as a standard step, precisely because the two documents being prepared independently, even by the same advisor, can otherwise drift apart.

You very likely still owe a TPDF. The disclosure threshold under Ministerial Decision No. 97 of 2023 is materially lower than the Local File and Master File thresholds, so a taxable person can have a full disclosure obligation while having no requirement to build the heavier documentation at all. This is, in fact, the most common profile PNPC sees.

We do not rely on a client's self-declared list. We map the actual ownership and control chain against Article 35's definitions — shareholder registers, group organisational charts, and where relevant, indirect ownership through common shareholders or family control — and separately identify Connected Persons under Article 36 from director registers and known family relationships. Only once that map is confirmed do we screen transactions for disclosure.

The FTA can request supporting detail or clarification for any disclosed related-party transaction or Connected Person payment. Having a reconciliation working paper — tracing the figure to the ledger and the accounts, and where relevant to a Local File's benchmarking conclusion — is what allows a query to be answered quickly and credibly, rather than triggering a broader review of the entire filing.

The Federal Tax Procedures Law (Federal Decree-Law No. 28 of 2022, as amended) and its implementing Cabinet Decisions on administrative penalties set the general penalty framework for tax non-compliance, which extends to incorrect or incomplete Corporate Tax return schedules including the related-party disclosure. Because exact administrative penalty amounts are fixed by Cabinet Decision and can be revised, PNPC confirms the current schedule with clients rather than quoting a figure that may be outdated.

Yes. PNPC can act as authorised tax agent on EmaraTax and file the Corporate Tax return, including the related-party disclosure schedule, directly, or prepare the reconciled schedule for the client's own finance team to submit under their own EmaraTax credentials — whichever the client prefers.

Corporate Tax computations and related-party disclosures are ultimately expressed in AED, so foreign-currency related-party transactions need converting using a consistently applied exchange rate methodology. PNPC documents the conversion approach used and applies it uniformly across the ledger, the accounts and the disclosure figures, so the three do not diverge from using different rates in different places.

For a taxable person with an already-verified related-party map and reasonably organised financial records, disclosure preparation and filing typically takes a matter of weeks, timed to the Corporate Tax return due date. A first-time engagement, where the related-party and Connected Person mapping has to be built from scratch, takes longer — the mapping and reconciliation work, not the form itself, is the time-consuming part.

Yes, for most taxable persons — the disclosure obligation runs alongside the Corporate Tax return itself, so a first-time Corporate Tax filer with related-party or Connected Person transactions above the disclosure threshold is filing the TPDF for the first time in the same cycle. PNPC treats first-year engagements as requiring the full related-party mapping exercise before any figures are populated, rather than assuming a shortcut is available because it is a new filing relationship.

Yes. Where a figure on a previously filed disclosure form is later found to be inaccurate or incomplete, it can be corrected through the amendment process available for the Corporate Tax return on EmaraTax. PNPC recommends correcting a known error proactively rather than waiting for the FTA to raise it, and documents the reason for the change alongside the original reconciliation working papers.

Where a taxable person is part of a Tax Group, the Corporate Tax return — and the related disclosure position — is generally handled at the level determined by the Tax Group's own filing arrangements, with the representative member coordinating the consolidated position. PNPC confirms which entity's related-party and Connected Person data feeds the disclosure and how transactions between Tax Group members themselves are treated, before assuming the same approach used for a standalone taxable person applies unchanged.

The taxable person's own disclosure obligation is not automatically removed by the counterparty's exemption status — the analysis starts from whether the counterparty is a Related Party or Connected Person of the taxable person under Articles 35 and 36, and whether the transaction value crosses the disclosure threshold. PNPC reviews the specific counterparty's status as part of the related-party mapping rather than assuming an exemption on one side of the transaction removes the disclosure requirement on the other.

Yes, where the branch has related-party or Connected Person transactions — including dealings with its own foreign head office or other group entities — above the disclosure threshold. A branch is assessed on the same Article 34 to 36 basis as any other UAE taxable person for this purpose.

The disclosure schedule expects transactions to be identified by category and counterparty, so an aggregated ledger line covering several distinct transaction types with the same or different related parties needs to be unpacked before it can be correctly mapped onto the form. PNPC works from the underlying transaction detail, not the aggregated ledger presentation, specifically to avoid misclassifying or under-disclosing what is actually several different arrangements bundled into one line.

The disclosure obligation is not conditional on the UAE having an information exchange arrangement with the related party's jurisdiction — it turns on the relationship and transaction value meeting the Article 35/36 and Ministerial Decision No. 97 of 2023 tests, regardless of where the counterparty is based or what exchange arrangements exist with that jurisdiction.

Yes, in principle. Article 36 addresses payments or benefits provided to Connected Persons, which can extend beyond cash payments to benefits-in-kind such as the free or below-market use of company assets or premises by an owner or director. PNPC identifies non-monetary benefits during the Connected Person inventory stage rather than limiting the review to cash payroll and rent entries alone.

Both directions of a shareholder or director loan relationship are relevant to the Connected Person disclosure — a loan from the company to the director is a Connected Person payment in its own right, distinct from any loan the director has separately advanced to the company, and each needs its own interest rate, tenure and value assessed.

A change of auditor does not itself change the underlying transaction figures, but if the change coincides with a shift in accounting presentation or classification of related-party balances, PNPC checks that the figures feeding the disclosure form remain consistent with how the same transactions were reported in the prior period, so a presentation change is not mistaken for a substantive change in the transaction itself.

Yes. An initial scoping conversation — reviewing the group structure, a rough sense of related-party transaction values, and Connected Person payments — is usually enough to give a reasoned initial view of whether the disclosure threshold is likely crossed, before a full mapping and reconciliation engagement is scoped and priced.

Useful starting materials include a current ownership chart or shareholder register, a list of related UAE and foreign entities, details of any owner or director remuneration and premises arrangements, the latest financial statements, and any Corporate Tax registration details already obtained. With those, PNPC can give an initial view of the disclosure position without waiting for the full documentation set.

EmaraTax and Corporate Tax return submissions are generally available in both Arabic and English, and the FTA accepts correspondence in both languages in practice. PNPC prepares underlying reconciliation and working papers in English as standard, arranging Arabic where a specific submission or FTA request calls for it.

The disclosure schedule is filed as part of the Corporate Tax return on EmaraTax, so there is no standalone government filing fee specific to the TPDF itself, separate from the Corporate Tax return filing process generally. PNPC's fee for TPDF preparation is a professional fee for the mapping, reconciliation and population work, quoted separately from any authority charges associated with the broader Corporate Tax filing.

PNPC's first step is establishing exactly which prior periods the disclosure threshold was actually crossed in, based on the real transaction and Connected Person values for each year rather than an assumption carried forward from the current year, and then advising on the appropriate route to bring the position current, which may include a voluntary disclosure depending on how the gap arose.

A related-party arrangement provided for no consideration is still a related-party transaction for disclosure purposes if it falls within a disclosable category — the absence of a price does not remove the relationship or the arrangement from scope, though it may itself be a point the FTA questions from an arm's length perspective, since related parties would not typically provide services to each other for free without an arm's length reason.

Not automatically, and this needs to be confirmed rather than assumed. Corporate Tax computation for a Tax Group involves consolidation of results for tax computation purposes, but the disclosure treatment of transactions between Tax Group members, and the treatment of any transactions with related parties outside the Tax Group, needs to be separately confirmed against current FTA guidance rather than assumed to disappear once a Tax Group exists.

Related-party status under Article 35 is assessed against the ownership and control position as it actually stood during the period the transaction occurred, so a share transfer partway through the year can mean a counterparty was a related party for part of the period and not for the rest, or vice versa. PNPC maps the ownership position by the relevant transaction dates rather than applying a single year-end snapshot across the whole period.

Yes, in principle — a natural person conducting Business or Business Activity in the UAE that is a taxable person under the Corporate Tax Law is subject to the same Article 34 to 36 related-party and Connected Person rules as a juridical person, and the disclosure obligation applies on the same basis once the relevant thresholds are crossed.

Yes, as standard practice on a take-on engagement. PNPC reviews the prior two to three years of filed disclosure forms and the underlying Corporate Tax returns for continuity, checks whether a related-party map was properly documented behind them, and flags any gap or inconsistency found before building the current year's filing on top of an unverified prior position.

The Corporate Tax return, including the disclosure schedule, can be filed by the taxable person itself or through an FTA-registered Tax Agent acting on its behalf. PNPC files as an FTA-registered Tax Agent where clients prefer PNPC to handle submission directly, rather than through an unregistered intermediary.

Where premises are shared among related entities without a formal lease or clearly allocated cost, PNPC works with the client to establish the actual arrangement — who legally holds the lease, how cost is or should be allocated among the occupying entities, and whether any entity is receiving free or below-market occupancy from a related landlord — before determining what, if anything, needs to be disclosed as a related-party or Connected Person arrangement.

Yes — whether the related party is privately held or publicly listed makes no difference to the Article 35 related-party test or the disclosure obligation. What matters is the ownership or control relationship and the transaction value, not the counterparty's listing status.

Corporate Tax related-party disclosure and VAT's own treatment of related-party or connected-person supplies (including the market-value rule for certain related-party supplies) are governed by separate rules and apply to the same underlying transaction for different purposes. PNPC checks that a related-party transaction's Corporate Tax disclosure treatment and its VAT treatment do not tell contradictory stories, without assuming that one automatically determines the other.

The Connected Person test under Article 36 looks at who held the relevant relationship — owner, director, officer, or relative — at the time the payment or benefit was provided, not at filing date. A former director who received a Connected Person payment while still in office is assessed on that basis for the relevant period, even if they have since left the company.

In PNPC's experience, the most common trigger is a disclosed figure that does not reconcile cleanly to the audited or management financial statements for the same period — whether from netting related-party balances differently between the accounts and the schedule, an inconsistent exchange rate, or a Connected Person payment captured in the accounts as ordinary payroll but omitted from the related-party disclosure. Getting the reconciliation right before filing is the single highest-value step in the whole exercise.