Transfer Pricing Disclosure Form (TPDF) Filing: What It Actually Involves
The Related Party Transactions disclosure form is the schedule most UAE taxable persons meet first on the transfer pricing spectrum — filed with every Corporate Tax return via EmaraTax the moment related-party or connected-person transactions cross the disclosure threshold, whether or not a Local File or Master File is ever required. Getting the form right sounds mechanical until the figures have to reconcile exactly to the audited accounts, every Connected Person payment has to be correctly captured under Article 36, and a mismatch becomes the single most common trigger for an FTA follow-up query. PNPC's Dubai desk populates the disclosure form as the final, reconciled output of a proper related-party mapping exercise — not a standalone form-filling task — so the numbers on EmaraTax match the numbers in your books and the numbers a benchmarking study, if one exists, already supports.
Understanding the Service
The Related Party Transactions disclosure form (commonly referred to as the TPDF, or Transfer Pricing Disclosure Form) is a schedule filed alongside the UAE Corporate Tax return on the Federal Tax Authority's EmaraTax portal, disclosing a taxable person's transactions and arrangements with Related Parties and payments or benefits provided to Connected Persons for the relevant tax period. It is the broadest and most frequently triggered of the UAE's transfer pricing compliance obligations under Federal Decree-Law No. 47 of 2022 and its implementing Ministerial Decision No.
For the full scope, current process and what PNPC includes, see the dedicated Transfer Pricing Disclosure Form (TPDF) Filing service page.
Signs This Applies to You
- The taxable person has related-party transactions — with a foreign parent, subsidiary, sister company, or a UAE group entity under common ownership including a mainland-Free Zone pairing — above the disclosure threshold prescribed under Ministerial Decision No.
- Owners, directors, officers or their relatives receive salary, rent, or loan interest from the company that qualifies as a Connected Person payment under Article 36, above the applicable disclosure threshold
- The Corporate Tax return for the period is being prepared and the taxable person has not yet confirmed whether its related-party or connected-person transaction values cross the disclosure threshold for the year
- The business sits below the Local File and Master File thresholds but still has related-party dealings that need to be correctly identified, valued, and disclosed — the TPDF obligation is independent of the higher documentation thresholds
When It Isn't the Right Fit
- The taxable person has genuinely no related-party or connected-person transactions for the period — the disclosure obligation only engages where a qualifying relationship and transaction exist in the first place
- Related-party and connected-person transaction values sit clearly and comfortably below the prescribed disclosure threshold — worth a short confirmatory review rather than a full filing exercise, though PNPC recommends verifying this rather than assuming it
- The entity is an Exempt Person under the Corporate Tax Law or otherwise confirmed outside its scope, subject to the exemption conditions continuing to hold and being re-verified periodically
Questions We're Actually Asked
What exactly is the TPDF, and how is it different from a Local File?
The TPDF (Transfer Pricing Disclosure Form), formally the Related Party Transactions disclosure schedule, is filed with every Corporate Tax return on EmaraTax once related-party or Connected Person transaction values cross the disclosure threshold under Ministerial Decision No. 97 of 2023. It summarises transactions by category and counterparty. A Local File is a much more detailed, entity-specific document — business description, FAR analysis, method selection, benchmarking — required only once higher revenue thresholds are met, and produced to the FTA on request rather than filed with the return.
Who has to file the TPDF?
Any UAE taxable person with related-party transactions or Connected Person payments that cross the disclosure threshold prescribed under Ministerial Decision No. 97 of 2023, for the relevant tax period — regardless of whether the taxable person also meets the separate, higher thresholds for Local File or Master File preparation. This threshold is materially lower and catches far more UAE businesses than the documentation thresholds.
We only transact between UAE entities under common family ownership. Do we still need to file?
Yes, if those entities are related parties under Article 35 — which turns on ownership and control thresholds, not on whether a border was crossed. Two mainland companies, or a mainland entity and its own Free Zone affiliate, under common family control are related parties for Corporate Tax purposes, and their intercompany dealings are disclosable once they cross the threshold, exactly as a cross-border related-party transaction would be.
Getting This Right From the Start
Get the disclosure schedule reconciled correctly the first time — PNPC's Dubai desk turns TPDF filing into the confirmed output of a proper related-party mapping, not a last-minute form-fill before the Corporate Tax return deadline.
PNPC Global has advised Dubai businesses since 1986. Explore the full UAE Taxation & Regulatory Compliance practice for related services, or go straight to the Transfer Pricing Disclosure Form (TPDF) Filing page for specifics.
Specific rates, fees, thresholds and deadlines are set by the relevant authority and change over time — this article deliberately does not quote figures that could go stale. Confirm current numbers directly with PNPC or the official source before you act.