UAE Federal Tax Authority Issues Advance Pricing Agreement Guidance

Introduction

With the introduction of Corporate Tax and formal Transfer Pricing (‘TP’) rules in the UAE, business groups are increasingly focused on managing TP risk, ensuring certainty and avoiding disputes. One of the most effective mechanisms available to achieve this objective is an Advance Pricing Agreement (‘APA’) which is an advance agreement with Federal Tax Authority (‘FTA’) on TP methodology of covered transactions.

The legislative framework to enter into APAs with the UAE FTA is provided in Article 59 of the UAE CT law.

With much anticipation, the FTA has issued detailed procedural guidance on APAs, marking a significant milestone in the evolution of the UAE’s tax framework. APAs provide eligible taxpayers with upfront certainty on transfer pricing outcomes for controlled transactions, thereby reducing controversy and improving compliance outcomes.

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Published

January 23, 2026

temp Key Contacts

Nilesh Ashar

Senior Managing Director

Naishadh Soneta

Senior Managing Director

Sameep S Uchil

Senior Managing Director

Aastha Jain

Managing Director

Omar Qureshi

Managing Director

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