Related Party Transactions and Corporate Tax Implications in the UAE

Recent updates strengthen tax certainty for related party transactions. On December 30, 2025, the FTA released the first Advance Pricing Agreement (APA) Corporate Tax Guide (CTGAPA1). This launches a formal APA program for advance agreement on transfer pricing methodologies. Unilateral APAs for domestic controlled transactions accept applications from December 30, 2025. Cross-border unilateral APAs start in 2026, with exact dates to follow.

APAs require a materiality threshold of AED 100 million per tax period for included transactions. Eligible applicants include persons with related…