FTA clarifies downward TP adjustment rules for corporate tax
The UAE Federal Tax Authority (FTA) has recently issued Public Clarification CTP011¹, setting out its position on downward transfer pricing (TP) adjustments made by a Taxable Person in the Corporate Tax Return, along with the disclosure and documentation expected to support such adjustments.
The analysis — automated & source-checked
- Applies to
- Tax · UAE
- What to do
- Taxpayers making downward TP adjustments must disclose them in the Corporate Tax Return regardless of value, and prepare supporting documentation (rationale, benchmarking, reconciliation, symmetry evidence).
The UAE Federal Tax Authority has issued Public Clarification CTP011 on downward transfer pricing adjustments. Under Article 34(1) of the Corporate Tax Law, transactions between related parties must meet arm's length standard. Previously, downward adjustments required prior FTA approval. Now they are self-assessed but subject to mandatory disclosure in the Tax Return and supporting documentation including rationale, benchmarking, reconciliation, and evidence of symmetrical adjustment from the related party. Upward adjustments remain subject to standard disclosure thresholds. Taxpayers should prepare documentation contemporaneously and ensure symmetry with counterparties.
Source
Reported by: Mondaq 20 Jul 2026 Read the original ↗ More from Mondaq →
Quick answers
What do I need to do?
Taxpayers making downward TP adjustments must disclose them in the Corporate Tax Return regardless of value, and prepare supporting documentation (rationale, benchmarking, reconciliation, symmetry evidence).
Who reported this?
Mondaq (UAE).
When was it announced?
20 Jul 2026.
Where can I read the original?
Read the original at Mondaq: https://www.mondaq.com/corporate-tax/1819846/uae-fta-clarifies-on-downward-tp-adjustments
Subscribe — free
Get the next change before it's a deadline
The whole front, every morning. Free.