UAE Transfer Pricing: Law 62/2025, Safe Harbours and Documentation

The UAE’s transfer pricing regime takes its statutory shape with Federal Decree-Law No. 62 of 2025 (the TP law), the framework that follows the introduction of the 9% corporate tax and gives the UAE’s international related-party transactions their arm’s length standard — with the characteristic UAE instruments: the safe harbours (the prescribed position for the routine fact patterns, in the same design family as India’s section 92CB harbours) and the documentation obligation. For the Indian group with a UAE affiliate — the distribution hub, the service centre, the treasury node — the UAE side is the new jurisdiction the file must answer, and the practice is being built as the law’s implementing practice settles. This guide is the framework map, at the level the law provides; the implementing details (the authority’s guidance, the forms, the practice) should be confirmed against the current implementing instrument before the position is filed.

The scope

The law’s operation, on the standard architecture:

• The transactions — the international transactions between related parties: the transaction between the UAE entity and its associated persons (the related-party standard — the control and the ownership limbs, on the jurisdiction’s definitions), where the transaction crosses the border. The domestic related-party transactions are outside the cross-border scope (the UAE’s framework is oriented to the international transactions, as the OECD-standard regime for the hub economy).
• The standard — the arm’s length principle: the terms of the controlled transaction are the terms that independent parties would have agreed, in the same circumstances — the OECD principle, the OECD methods (the CUP, the TNMM, the cost plus, the profit split) as the practice, the same method set as the methods overview.
• The entities — the UAE entities with the international related-party transactions: the free-zone entities and the mainland entities, the corporate-tax-registered entities in scope for the 9% regime — the TP obligation attaching to the taxable entity’s controlled transactions.

The hub-economy reading: the UAE affiliate is typically the distribution node, the service centre or the treasury node of the group — the limited- risk distributor, the shared-service provider, the intercompany lender — and the TP questions are the hub’s questions: the distributor’s margin, the shared-services benefit and allocation, the intercompany finance — the routine fact patterns, in the jurisdiction that exists to host them.

The safe harbours

The UAE law’s characteristic instrument, in the design family of the standardized returns:

Harbour	The fact pattern	The prescribed position
The services cost-plus	The routine intra-group services — the low-value-adding, the administrative, the support services performed by the UAE entity for the group	A prescribed cost-plus margin on the eligible services: cost plus the fixed margin, the benchmark fight removed — the LVAS logic in the UAE’s prescriptive form, and the Amount B family’s regional expression
The deposit position	The intercompany deposits — the UAE entity’s net deposit position in the group’s cash structure (the treasury node’s funding of the group)	A prescribed deposit return on the net deposit balance: the deposit character’s arm’s length return, the cash-pooling economics at the prescribed position

The design logic is the Indian logic, in the UAE form: the routine fact pattern gets the prescribed return — the certainty instrument that ends the comparables fight for the fact pattern the jurisdiction hosts in volume. The strategy is the safe harbour strategy applied to the UAE harbours: the benchmark run anyway (the decision made knowing where the range sits), the election where the certainty is worth the band, the benchmark position where the entity’s return is above the harbour and the matrix is strong.

The working caution: the implementing details — the eligible-service definitions, the margin’s level, the value limits, the election mechanism, the interaction with the free-zone regimes — are at the implementing-instrument level, and the position should be confirmed against the current guidance before the harbour is relied on. The framework (harbour for the routine, benchmark for the rest) is the law’s; the parameters are the guidance’s.

The documentation

The documentation obligation, on the OECD standard:

• The standard — the arm’s length documentation for the controlled transactions: the entity’s description (the FAR), the transactions, the method and the rationale, the benchmarking (the comparables, the adjustments, the range), the financials — the OECD Local File skeleton, as in the other jurisdictions.
• The contemporaneity — the documentation prepared as part of the annual compliance, on the year’s actuals — the contemporaneous file as the standard, the reconstruction as the credibility failure, in the same structural role as the Indian 31 May window.
• The production — the documentation available for the authority’s request — the maintain-and-produce standard, the file that is the retrieval, not the construction.

The cross-border reading, as in the other hubs: the UAE file and the Indian file are two presentations of the same group economics — the same transactions (the distribution flow, the services flow, the finance flow), the same pricing, the two jurisdictions’ documentation. The group that documents once, to the OECD standard, serves both; the documentation that answers one list and not the other carries the gap.

The deadlines and the compliance cycle

The compliance cycle, on the law’s architecture (the specific dates per the implementing instrument — confirmed against the current guidance):

1. The corporate tax return — the UAE entity’s 9% corporate tax return, the TP positions within it (the controlled transactions’ arm’s length pricing reflected in the computation).
2. The TP documentation — prepared in the annual cycle, on the year’s actuals, per the standard above.
3. The harbour elections — where the safe harbours are used: the election/declaration per the implementing mechanism, the position declared at the prescribed margin.
4. The retention — the documentation retained per the law’s period (the corporate-tax records period), retrievable for the examination.

The working position for the group with a UAE node

1. The node’s characterization first — the UAE entity’s function (the distributor, the service centre, the treasury node) fixed on the FAR — the characterization that determines the method, the harbour eligibility, and the documentation.
2. The harbour decision, per transaction stream — the services (the cost-plus harbour), the deposit (the prescribed return), the rest (the benchmark) — the harbour strategy on the UAE parameters, confirmed against the implementing guidance.
3. The OECD documentation, serving both — the UAE file and the Indian file, the same economics, the two jurisdictions’ lists — the documentation pillar discipline.
4. The two-jurisdiction consistency — the pricing that holds in both directions, the MAP/correlative readiness where it does not.

See also

• Jurisdiction comparison — the six-jurisdiction table
• India safe harbours — the design family
• Shared services — the hub fact pattern
• Intercompany finance — the treasury node