How UAE Businesses Are Entering the Age of Transparency, Transfer Pricing & True Accountability
- FTA’s Lens: Data, Depth, and Diligence
- Transfer Pricing: The Silent Storm Ahead
- Substance Over Forms, Always Wins
- Beyond Deadlines, Toward Discipline
As of 30 September 2025, the first major UAE Corporate Tax filing season has officially ended. Tens of thousands of businesses across the Emirates have now submitted their inaugural tax returns — a historic moment marking the UAE’s transition from tax-free to tax-transparent. But if you think the story ends with filing, think again. For most businesses, the return was just the trailer — the movie starts now.
From Filing to Facing Reality
The first year of Corporate Tax compliance was about learning the form. The next will be about proving the substance. The Federal Tax Authority (FTA) now holds detailed information on group structures, related-party transactions, and profit allocations. The coming year will be defined by transfer pricing reviews, data validation, and economic substance checks — not just return submissions. Businesses that treated this as a one-time compliance event will soon realize that the true challenge is sustained documentation, governance, and consistency.
Transfer Pricing: The Silent Audit Begins
For many UAE companies, Transfer Pricing (TP) has quietly become the next frontier. The FTA will be asking new questions: How were intercompany service fees determined?, Why is one entity’s margin higher than another’s?, Do your agreements reflect real-world decision-making and risks?
Those who prepared Master Files, Local Files, and benchmarking studies early will now find themselves ahead of the curve. Those who didn’t — may find their numbers under the microscope.
What the First Filing Revealed
Across sectors — real estate, trading, logistics, healthcare, and finance — a few clear patterns have emerged: Many companies underestimated the level of data granularity the FTA requires. Related-party disclosures forced groups to finally map their true value chains. Businesses realized that economic substance and transfer pricing are not separate silos — they tell the same story from two angles. In short: the first filing was a mirror, and some didn’t like the reflection.
The Second Year Will Be Different
Year one was about compliance, Year two will be about credibility. As groups refine their policies, the focus will shift to: Aligning TP documentation with operational substance, Reviewing intercompany agreements and pricing models, Building internal tax control frameworks, Training finance teams on continuous compliance instead of annual panic. Those who make these shifts now will convert Corporate Tax from a burden into a competitive advantage.
The UAE’s New Business Language: Transparency
The UAE has officially entered a new era — one where growth and governance go hand-in-hand. Corporate Tax is not a penalty for success; it’s a platform for trust, investment, and international credibility. When businesses show that their profits are earned — and priced — fairly, the UAE’s position as a global financial hub only strengthens.
Closing Thoughts: From Deadline to Discipline
The filing deadline may have ended, but the discipline has just begun. 2025 will be remembered not just as the year of the first Corporate Tax return — but as the beginning of a culture of accountability. For those ready to adapt, document, and defend — the next chapter of the UAE’s tax landscape is full of opportunity.
