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22 Aug, 2025

UAE Corporate Tax Filing Deadlines September 2025: Transfer Pricing Adjustments and Audit Readiness Guide

Legal Disclaimer:
The content in this article is for general informational purposes only. It does not constitute legal, financial, or tax advice. Readers should consult with a qualified professional, such as DP Taxation, for guidance specific to their individual circumstances. Tax laws and regulations are subject to change, and professional guidance is recommended for compliance.

As businesses across the United Arab Emirates prepare for the September 2025 corporate tax filing deadline, ensuring compliance with the UAE’s evolving tax landscape is critical. Companies with financial years ending on December 31, 2024, must submit their first full-year corporate tax return by September 30, 2025. This filing obligation applies to both mainland entities and Qualifying Free Zone Persons (QFZPs), each of whom must ensure that related-party transactions adhere to the arm’s length principle, that transfer pricing adjustments are documented properly, and that Pillar Two requirements under the Domestic Minimum Top-up Tax (DMTT) are met.

Meeting these obligations is not only essential to avoid penalties but also to maintain credibility with the Federal Tax Authority (FTA). At DP Taxation, we guide businesses through every aspect of corporate tax compliance, from transfer pricing and documentation to audit readiness and Pillar Two calculations, ensuring all filings are accurate and defensible.


UAE Corporate Tax Filing Deadlines

The Federal Decree-Law No. 47 of 2022 mandates that all corporate tax returns be submitted electronically via the FTA EmaraTax portal within nine months of the financial year-end. For companies with a December 31, 2024 year-end, this means a firm deadline of September 30, 2025. Tax payments are due by the same date.

While extensions are not generally granted, the FTA has occasionally implemented initiatives to provide relief for late registrants. For instance, companies registering late for corporate tax were allowed to submit their 2024 returns by July 31, 2025, to avoid penalties, with tax payments still required by September 30, 2025. Despite these exceptions, businesses should plan to meet the official deadline, as relying on potential extensions could result in penalties or audit exposure.


Transfer Pricing Compliance in the UAE

Transfer pricing is central to corporate tax compliance. All related-party transactions must be conducted at arm’s length, with proper documentation submitted through the TP Disclosure Form in the EmaraTax portal. Materiality thresholds apply: transactions with a cumulative value exceeding AED 40 million, per-category transactions over AED 4 million, or transactions with connected persons above AED 500,000 trigger disclosure requirements.

Additionally, multinational groups with global revenues exceeding AED 3.15 billion must prepare a Master File, while UAE entities with revenues over AED 200 million require a Local File. Benchmarking studies, often using OECD-approved methods such as the Comparable Uncontrolled Price (CUP) or Transactional Net Margin Method (TNMM), are essential to demonstrate compliance. These studies analyze comparable uncontrolled transactions to justify pricing and support arm’s length adjustments.

To streamline TP documentation, businesses can leverage software solutions such as Coperitas, which automate data collection, provide structured filing templates, and enhance audit readiness. Using these tools in combination with expert guidance from DP Taxation ensures businesses can meet both TP disclosure and audit requirements effectively.


Pillar Two and the Domestic Minimum Top-up Tax (DMTT)

The UAE has implemented the DMTT for financial years starting on or after January 1, 2024, in line with OECD Pillar Two Global Minimum Tax rules. This tax is designed to ensure that multinational groups with consolidated revenues of €750 million or more achieve a minimum 15% effective tax rate (ETR) within the UAE.

For QFZPs, even if their corporate tax rate is 0% on qualifying income, the DMTT may still apply to ensure that the group-wide ETR meets the 15% threshold. Transfer pricing adjustments are particularly relevant here because mispriced related-party transactions can distort taxable income and lead to a higher DMTT liability. Businesses that accurately document TP adjustments and benchmarking studies are better positioned to minimize top-up tax exposure and demonstrate compliance to the FTA.

 


Penalties for Non-Compliance

The FTA’s penalty framework is clearly defined:

  • Late filing: AED 500 per month for the first 12 months; AED 1,000 per month thereafter.
  • Late payment of tax: 1% per month on the unpaid amount.
  • Failure to submit TP documentation: AED 500,000.
  • Incorrect or incomplete returns: AED 20,000.

Failure to comply with corporate tax obligations not only incurs these fines but also increases the risk of an FTA audit. Businesses should prioritize early preparation, ensuring accurate filings and supporting documentation are in place well ahead of the September 30, 2025 deadline.


Preparing for September 2025: Recommended Approach

Early planning is key. Companies should first confirm tax registration on the EmaraTax portal. Next, they should map all related-party transactions, both domestic and cross-border, to determine which require disclosure. Completing TP documentation, including Master File and Local File, is essential, with benchmarking studies updated for 2024 transactions.

Multinational groups should also assess Pillar Two/DMTT impact, calculating the UAE ETR and potential top-up tax. Tax computations should be finalized, ensuring corporate tax and DMTT liabilities are properly modeled. Finally, conducting a mock audit of TP documentation, intercompany agreements, and filings will improve audit readiness and reduce risk of adjustments.

Leveraging technology such as Coperitas combined with expert consultation from DP Taxation allows businesses to automate data collection, maintain robust records, and simplify compliance with UAE TP and corporate tax obligations.


Frequently Asked Questions

1. What is the UAE corporate tax rate?
The standard rate is 9% on taxable income exceeding AED 375,000, while QFZPs may apply a 0% rate on qualifying income, subject to FTA criteria.

2. When is the filing deadline for December 31 year-end entities?
September 30, 2025, for first full-year corporate tax returns.

3. What penalties apply for late filing or payment?
AED 500/month for the first 12 months of late filing, AED 1,000/month thereafter, plus a 1% monthly penalty on unpaid tax amounts.

4. Which companies are subject to Pillar Two/DMTT?
Multinational groups with consolidated revenues ≥ €750 million.

5. How does DMTT affect QFZPs?
Even if corporate tax is 0%, profits may be subject to a 15% top-up to meet group-wide ETR requirements.


Best Practices for Compliance

Businesses should maintain robust intercompany agreements, TP documentation, and benchmarking studies, updating them regularly to reflect arm’s length pricing. Leveraging TP software solutions, such as Coperitas, can help automate and structure compliance. Engaging DP Taxation early ensures seamless navigation of complex UAE corporate tax and TP obligations, including Pillar Two readiness.


Conclusion

The September 2025 corporate tax filing deadline represents a critical compliance milestone for UAE businesses. Accurate transfer pricing documentation, audit readiness, and Pillar Two/DMTT planning are essential to minimize penalties and exposure to FTA audits. By leveraging expert guidance and software solutions, businesses can file confidently, maintain compliance, and focus on growth in the UAE’s dynamic economy.


 

 

 

References

  • UAE Ministry of Finance – Corporate Tax FAQs
  • Federal Tax Authority – Corporate Tax Law (Federal Decree-Law No. 47 of 2022)
  • Cabinet Decision No. 75 of 2023 – Administrative Penalties
  • OECD – Global Minimum Tax (Pillar Two)
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