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UAE FTA Clarifies Transfer Pricing Downward Adjustments - Relief for Taxpayers, but with Strings Attached
24/07/2026Many taxpayers assume that once a downward Transfer Pricing adjustment is made in the Corporate Tax Return, that's the end of the story. Under the UAE FTA's new Public Clarification CTP011, it isn't.
Any related party transaction tied to a downward adjustment now needs to be disclosed, regardless of size or materiality, and it needs to hold up under scrutiny.
Getting this right means having a clear arm's length analysis, supporting benchmarking, a reconciliation between accounting and tax figures, and evidence of how the related party treated the same transaction. The strongest position is one that's assessed during the financial statement close, not pulled together at tax return stage.
Sahil Sharma, Transfer Pricing Director breaks down what this clarification means for year-end TP provisioning.
Read more to understand what CTP011 means for your Transfer Pricing approach.