The introduction of the UAE corporate tax (CT) regime marks a pivotal shift in the country’s tax framework, formally embedding transfer pricing (TP) as a core compliance requirement for transactions undertaken by taxpayers with related parties and connected persons.
For UAE family-owned business groups, characterized by multi-entity ownership structures, integrated operating models and centralized decision making, this requires the existing business operating models to be reassessed through the lens of arm’s length pricing, documentation and compliance requirements.
Now that UAE taxpayers have concluded their first financial year under the CT regime, the focus is moving beyond initial compliance toward stabilizing and refining TP frameworks. While the first year was largely about understanding the rules, identifying related party transactions (RPTs), and meeting initial compliance obligations, the journey ahead calls for a more strategic approach, where TP is integrated into a group’s day-to-day operations rather than addressed as a year-end compliance exercise.
This report outlines key takeaways from the first year of TP implementation for UAE family-owned business groups as they transition into the second year of compliance. It emphasizes the importance of robust governance, highquality contemporaneous documentation, and alignment between operational conduct, financial reporting, and TP outcomes to support audit readiness and regulatory defensibility.
As the UAE continues to align with international tax standards, a proactive and structured TP approach will be critical for managing risk, supporting sustainable operations and navigating the evolving regulatory landscape.
