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.