UAE Federal Tax Authority Service Fees and APA Regulations for 2026

The United Arab Emirates (UAE) continues its evolution as a globally competitive tax environment by refining administrative frameworks and enhancing tax certainty tools. A major development in this respect is Cabinet Decision No. 174 of 2025, which introduces targeted amendments to the Federal Tax Authority (FTA) Service Fees structure and formally integrates the Advance Pricing Agreements (APA) regime into the fee framework, effective 1 January 2026. 

This article is aimed at delivering a factual, professionally organized brief that is designed to suit accounting professionals and corporate taxpayers in the UAE, specifically those who are planning to undertake compliance processes in 2026 and beyond.

What Are FTA Service Fees Under UAE Cabinet Decisions?

Federal Tax Authority (FTA) Service Fees refer to fees that are charged to the FTA in making official services to taxpayers and users of the services. These involve charges on issuing tax-related certificates, applications, and clarification request charges. It was originally scheduled by decree of the Cabinet No. 65 of 2020 and has been revised many times based on the changes in the administrative needs and compliance requirements.

Evolution of FTA Service Fees Framework

• Cabinet Decision No. 65 of 2020 first introduced the official schedule of fees for services provided by the FTA.
• Changes in the tax administration requirements changed this schedule by making interim changes through Cabinet Decision No. 7 of 2023 and Cabinet Decision No. 111 of 2023.
• Cabinet Decision No. 174 of 2025 (effective 1 January 2026) updates this schedule by introducing service fees related to Advance Pricing Agreements (APAs), representing a significant step in formalising advanced transfer pricing tools.

Core Services Covered and Fees

Under Cabinet Decision No. 65 of 2020 (with subsequent amendments), the FTA schedule includes—but is not limited to—the following services:

• Tax Residency Certificates – Fees differ depending on applicant type.
• Certificates for Commercial Activities – Issuance and copies attract fixed charges.
• Registration of Accounting Software Vendor Annual fee of compatible systems.
• Tax Agent Registration & Renewal – Applicable for natural and juridical persons.
• Private Clarifications – Fees for official clarification requests covering one or multiple taxes.

Introduction of APA Fees (Effective 1 January 2026)

The landmark feature of Cabinet Decision No. 174 of 2025 is the inclusion of APA-related fees within the FTA service schedule. Two new fee categories were added:

• AED 30,000 for submitting a request to conclude a unilateral Advance Pricing Agreement (APA) for the first time.
• AED 15,000 for renewing or amending an existing APA.

Such fees indicate the administrative and technical resources needed to examine APA applications and steer the UAE towards the international standards of tax administration.

Other existing FTA service fees are not altered by this amendment and they are still as they were originally established under the consolidated table of fees.

How Do APAs Affect Fees and Tax Certainty?

Advance Pricing Agreements (APAs) in Context

An aggressive regulatory instrument, the Advance Pricing Agreement (APA), provides transfer pricing certainty in complex related-party transactions. In the case of an APA, a taxpayer and the FTA will agree on the methodology to be used to apply the arm-length principle to transactions involving the specified transactions within a specific period of time. This process assists in reducing future tax conflicts, setting expectations, and increasing the predictability of multinational companies that conduct their operations in the UAE.

Types and Scope

Unilateral APA The unilateral APA is one where a single tax authority, in this case, the FTA, agrees with a taxpayer on how to transfer prices for UAE purposes only.
The bilateral or multilateral APAs that reflect more than one tax jurisdiction are likely to mature along with the development of the transfer pricing framework in the UAE. The existing fee provisions, however, dwell on unilateral APAs.

Fee Framework and Practice Impact.

Since the amended service schedule has brought about APA-related fees, the taxpayers are now subjected to a regulated fee regime when dealing with the FTA on transfer pricing certainty:

First APA Processing Fee – AED 30,000: It includes the application and early screening.
Renewal/Amendment Fee—AED 15,000: This applies to extending or amending the existing agreements.

Such charges are associated with the bureaucracy involved in rating APAs (usually through in-depth functional analysis, benchmark studies, and analysis of transaction structure).

Benefits of APAs

• Tax Certainty: APAs can offer a binding framework to minimize the risk of transfer pricing dispute and audit adjustment in future.
• Risk Management: APAs allow multinational enterprises to manage their tax exposures for profit allocation across related parties.
• Conformance with International Standards: The introduction of APAs will bring the UAE nearer to the transfer pricing practices accepted by OECD and which are widely used in other large jurisdictions.

Which Laws Govern FTA Fees and APA Applications?

Legal basis of FTA service fees like added APA fees is pegged on a combination of Federal Decree-Laws as well as Cabinet Decisions. These legislative provisions define FTA jurisdiction, fee rates and procedures.

Key Governing Laws

1. Constitution & Ministry Competencies
   The UAE Constitution and Federal Law No. 1 of 1972 on ministerial competencies underpin the federal regulatory framework, including tax administration structures.
2. Federal Decree-Law No. 13 of 2016
   Establishes the Federal Tax Authority, empowering it to administer federal tax laws and services.
3. Federal Decree-Law No. 28 of 2022 (Tax Procedures Law)
   Governs procedural elements for tax compliance, including interactions between taxpayers and the FTA.
4. Federal Decree-Law No. 7 of 2017 (Excise Tax) and Federal Decree-Law No. 8 of 2017 (Value Added Tax – VAT)
   Delineate the substantive tax regime of excise and VAT which overlaps with FTA services of clarifications and submission of compliance.
5. Federal Decree-Law No. 47 of 2022 (Taxation of Corporations and Businesses)
   Incorporates and regulates the corporate taxation system, in which transfer pricing and APA systems find their relevance.
6. Federal Decree-Law No. 26 of 2019 (Public Finance)
   Provides overarching public finance rules impacting government revenue mechanisms.

Cabinet Decisions

• Cabinet Decision No. 65 of 2020 on FTA Service Fees laid out the initial fee structure and remains the core reference for service-based charges.
• Cabinet Decision No. 7 of 2023 and No. 111 of 2023 amended the original schedule.
• Cabinet Decision No. 174 of 2025 adds APA fees and continues the evolving regulatory landscape for tax administration.

These decisions are published on the UAE Legislation Portal and the FTA’s official Legislation page, which also provide consolidated texts and unofficial translations for public reference.

Conclusion

The FTA service fee regime is part of the pillars of transparency and compliance in the UAE’s tax administration.

The decision of the cabinet No. 174 of 2025 is one significant step, as it includes the fees associated with APA into the formal service schedule that will occur on 1 January 2026. This trend underscores how the UAE is keen on adopting transfer pricing practices that are internationally aligned so that multinational corporations can have a system that reduces the risk of tax and enhances the certainty of taxation.

The business accounting practitioners and tax professionals should comply with these changes by revising the compliance procedures, estimating the cost of using the APA applications, and protecting procedural and substantive legal standards according to the UAE tax laws.