International Tax · UAE

International Tax Services in the UAE for Groups That Cross Borders

Transfer pricing files, Country-by-Country Reporting and the 15% Domestic Minimum Top-up Tax now land on the same finance desk. IMC maps which rules reach each UAE entity in a group and handles them as one coordinated engagement across India, the UAE and Singapore.

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  • Transfer pricing documentation
  • Pillar Two top-up tax
  • Country-by-Country Reporting
  • India, UAE and Singapore corridor

Key Thresholds

Four numbers that decide your UAE international tax obligations

Most of a group's international tax position in the UAE follows from four thresholds. Each one is tested on a different figure, which is where groups most often misread their position.

  • AED200m
    What it triggers

    Master file and local file

    How it is tested

    The UAE entity's own revenue in the tax period

  • AED3.15bn
    What it triggers

    Master file and local file for every UAE constituent entity, plus Country-by-Country Reporting for UAE-headquartered groups

    How it is tested

    Consolidated group revenue

  • AED40m
    What it triggers

    Transfer Pricing Disclosure Form with the Corporate Tax return

    How it is tested

    Total related party transactions in the period, with each category above AED 4m reported

  • EUR750m
    What it triggers

    15% Domestic Minimum Top-up Tax: registration, calculation and returns

    How it is tested

    Consolidated group revenue in at least two of the four preceding fiscal years

Thresholds as at October 2026. Each figure is referenced to its Ministerial or Cabinet Decision in the technical summaries below.

Group Profiles

Where does your group sit?

The same rules land very differently on a single free zone trading company and on a regional hub inside a global group. This table matches common group profiles to what applies and where the work starts.

Group profile What applies in the UAE Where IMC starts
UAE entity below AED 200m, group below AED 3.15bnArm's length pricing on every related party transaction; Disclosure Form if flows exceed AED 40mA light-touch pricing file and signed intercompany agreements
UAE entity at or above AED 200mMaster file, local file and Disclosure FormFunctional analysis and benchmarking
Qualifying Free Zone Person with related party flowsArm's length compliance as a condition of the 0% rateQualifying status review alongside transfer pricing support
Group at or above AED 3.15bnDocumentation for every UAE entity; Country-by-Country Report if UAE-headquarteredGroup-wide pricing policy and report alignment
Group at or above EUR 750m in two of four yearsTop-up Tax registration, effective tax rate calculation and returnsScope test, entity registration and data readiness

Our Services

International tax services in the UAE

Each service can run on its own, but most groups take two or three together because they draw on the same entity data and the same intercompany story.

  • Transfer Pricing Documentation

    Master file, local file, Disclosure Form and benchmarking, built to stand up in the UAE and in the counterparty's jurisdiction.

    Transfer pricing documentation in the UAE

  • Pillar Two and the Domestic Minimum Top-up Tax

    Scope testing, Top-up Tax registration, effective tax rate modelling and return preparation for in-scope groups.

    Pillar Two in the UAE

  • Intercompany Agreements and Policy

    Agreements and group pricing policies written to match how each entity actually operates, so contracts and documentation tell the same story.

  • Cross-Border Structuring Review

    Holding, mainland and free zone structures reviewed against Corporate Tax, transfer pricing and the 15% floor at the same time.

  • Country-by-Country Reporting

    Report preparation for UAE-headquartered groups, reconciled to the master file and the group's consolidated accounts.

  • FTA Information Requests

    Structured responses to Federal Tax Authority queries on related party transactions, backed by the documentation already on file.

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Cross-Border Corridor

One analysis, defended in two jurisdictions

Every intercompany transaction has two ends. When an Indian parent charges its Dubai subsidiary for management services, the UAE local file tests the cost and India's Form 3CEB tests the income. Advisers who see only one side tend to produce two analyses that do not quite agree, and that gap is exactly what tax authorities look for.

IMC works across India, the UAE and Singapore as a member of Andersen Global. The functional analysis, comparables and pricing policy are built once and adapted for each authority, so the group presents a single, consistent position wherever it is reviewed.

Built for the corridor

Groups with a parent in India or Singapore and an operating, holding or free zone entity in the UAE get one team, one data request and one set of numbers.

  • INIndia
  • AEUAE
  • SGSingapore

  • UAE

    Key transfer pricing filing
    Master file, local file and Disclosure Form
    What IMC keeps aligned
    Tested party, method and arm's length range

  • India

    Key transfer pricing filing
    Form 3CEB and Form 3CEAA master file
    What IMC keeps aligned
    Service descriptions, cost base and markup

  • Singapore

    Key transfer pricing filing
    Transfer pricing documentation where thresholds apply
    What IMC keeps aligned
    Group policy and intercompany agreements

Technical Library

Technical library

Two working references for finance and tax teams, each reviewed against the current Ministerial and Cabinet Decisions. Free to download: share a few details and we will email the PDF to you.

  • Transfer pricing

    UAE Transfer Pricing Documentation: Technical Summary 2026

    Thresholds, file contents, the Disclosure Form and free zone conditions in one reference.

    Get the PDF by email
  • Pillar Two

    UAE Pillar Two Scoping Guide 2026

    Scope test, registration and return calendar, and a readiness checklist for in-scope groups.

    Get the PDF by email

Further reading: IMC's analysis of what the 15% domestic minimum tax means for multinational structures (Mondaq, March 2026).

How We Work

How an engagement runs

  1. Scope

    The entity chart and current figures are tested against every threshold, entity by entity.

  2. Diagnose

    Related party flows, free zone status and effective tax rate exposure are reviewed together.

  3. Document

    Files, agreements, registrations and returns are prepared from one consistent data set.

  4. Maintain

    An annual refresh keeps the position current as figures, rules and structures change.

Get Started

See every UAE entity's position on one page

A scoping call with IMC's international tax team walks through the group's thresholds, upcoming dates and the first steps for each UAE entity.

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FAQs
International tax advisory in the UAE covers the rules that apply when a business deals with related entities or operates as part of a group across borders. For most groups this means transfer pricing under Articles 34 and 55 of the Corporate Tax Law, Country-by-Country Reporting for large UAE-headquartered groups, and the 15% Domestic Minimum Top-up Tax for multinationals above the Pillar Two threshold. It also covers treaty access, withholding questions in the counterparty jurisdiction, and how profit is allocated between mainland, free zone and overseas entities in the same group.
A free zone company must price its related party transactions at arm’s length, exactly as a mainland company does. Whether a full master file and local file is required depends on the AED 200 million entity revenue test and the AED 3.15 billion group test. For a Qualifying Free Zone Person the stakes are higher, because arm’s length compliance and the Article 55 documentation rules are conditions for the 0% rate. Losing qualifying status affects the current period and the following four tax periods, so most free zone groups keep supporting analysis on file.
The two numbers sit close together but answer different questions. AED 3.15 billion is the consolidated group revenue test for transfer pricing documentation and Country-by-Country Reporting, read for the relevant tax period. EUR 750 million is the Pillar Two scope test, and a group is in scope only if it reaches that level in at least two of the four fiscal years before the year being tested. A group can therefore cross one line a year or more before the other, which is why IMC tests both from the same consolidated figures.
A group below the threshold has no Top-up Tax registration or filing obligation in the UAE. It is still worth tracking group revenue against the two-of-four-years test, especially for fast-growing groups and those planning acquisitions, because crossing the line brings registration, data collection and effective tax rate calculations within a short window. Groups approaching the threshold also benefit from shaping transfer pricing policies and entity substance with the 15% floor in mind, so the structure does not need reworking once the group comes into scope.
A single functional analysis and benchmarking exercise can support both sides of an India to UAE transaction, provided it is designed for both regimes from the start. India’s Form 3CEB and the UAE local file look at the same transaction from opposite ends, and the tested party, comparables and method need to make sense in each jurisdiction. IMC prepares the analysis once and adapts the documentation for each tax authority, which keeps pricing consistent and reduces the chance of one side adjusting what the other side accepted.
A useful starting pack includes the legal entity chart with ownership percentages, the latest audited financial statements for each UAE entity, consolidated group revenue for the past four years, and copies of intercompany agreements. A schedule of related party transactions by type and value shows quickly which documentation thresholds apply. For groups near the Pillar Two threshold, Country-by-Country Report data and current tax provisions by jurisdiction are also useful. Gaps in this pack are common, and closing them is usually the first output of a review.
IMC’s international tax work in the UAE is built around groups whose parent company sits outside the UAE, particularly in India and Singapore. Because IMC operates across all three jurisdictions as a member of Andersen Global, the same team can look at the parent’s position and the UAE subsidiary’s position together. That matters for transfer pricing, where two tax authorities review the same transaction, and for Pillar Two, where most of the data needed for UAE calculations sits in the parent company’s consolidation.
The technical summaries on this page are free to download and are written as a working reference for finance and tax teams. Each one sets out the relevant thresholds, deadlines and documentation requirements in a single view, with references to the underlying Ministerial and Cabinet Decisions. They are general guidance and reflect the rules as at the review date printed on each document. UAE tax guidance has been updated several times since 2023, so groups should confirm the current position against their own facts before acting.