What Are UAE FTA Service Fees Under Cabinet Decision No. 174 of 2025?
The UAE continues to refine its tax administration framework by updating the fees charged for official Federal Tax Authority (FTA) services. Cabinet Decision No. 174 of 2025 is the latest amendment to this fee structure, and it does something the earlier versions did not: it formally brings Advance Pricing Agreements (APAs) into the FTA’s fee schedule, effective 1 January 2026.
FTA service fees are the administrative charges the authority collects for issuing tax certificates, processing applications, and responding to clarification requests. The fee schedule was first introduced under Cabinet Decision No. 65 of 2020 and has been revised several times since as compliance requirements and administrative needs evolved.
This article sets out what changed under Cabinet Decision No. 174 of 2025, what the new APA fees mean in practice, how the application process works, and which businesses are most likely to need a unilateral APA in 2026.
Evolution of the FTA Service Fees Schedule
The FTA fee structure has developed in stages rather than in one single document:
- Cabinet Decision No. 65 of 2020 introduced the original schedule of fees for FTA services.
- Cabinet Decision No. 7 of 2023 and Cabinet Decision No. 111 of 2023 made interim amendments as administrative requirements changed.
- Cabinet Decision No. 174 of 2025, effective 1 January 2026, adds a dedicated fee category for Advance Pricing Agreements, marking the first time APA-specific fees have appeared in the schedule.
Fees for services that existed before this amendment, such as tax residency certificates and tax agent registration, are not altered by Cabinet Decision No. 174 of 2025. They remain governed by the earlier schedule.
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Core FTA Services Covered by the Fee Schedule
Under Cabinet Decision No. 65 of 2020 and its subsequent amendments, the FTA fee schedule covers a range of administrative services, including:
- Tax Residency Certificates: fees vary depending on whether the applicant is a natural person or a juridical person, and whether they are already registered with the FTA.
- Certificates for Commercial Activities: fixed charges apply for issuance and for additional copies.
- Registration of Accounting Software Vendors: an annual fee applies for vendors whose systems are certified as FTA-compatible.
- Tax Agent Registration and Renewal: applicable to both natural persons and juridical persons acting as registered tax agents.
- Private Clarifications: fees apply for formal clarification requests, whether they cover a single tax type or multiple taxes.
The precise fee amounts for these services should always be confirmed against the FTA’s current published schedule, since figures can be updated by future Cabinet Decisions without a change in the underlying service description.
Also check: Transfer Pricing Services in Dubai, UAE
New APA Fees Introduced by Cabinet Decision No. 174 of 2025
The headline change under Cabinet Decision No. 174 of 2025 is the introduction of two new fee categories tied specifically to Advance Pricing Agreements:
- AED 30,000 for submitting a request to conclude a unilateral APA for the first time.
- AED 15,000 for renewing or amending an existing APA.
These fees reflect the administrative and technical work involved in reviewing an APA application, including evaluation of the taxpayer’s functional analysis, benchmarking study, and proposed transfer pricing methodology. Businesses budgeting for a 2026 APA filing should treat these figures as the starting point and confirm the current amounts directly with the FTA or a transfer pricing advisor before submission, since Cabinet Decisions of this kind can be revised.
UAE FTA Service Fees at a Glance: Before and After Cabinet Decision No. 174 of 2025
| Fee Category | Position Before 1 January 2026 | Position From 1 January 2026 |
|---|---|---|
| Unilateral APA, first submission | No dedicated fee category existed | AED 30,000 |
| APA renewal or amendment | Not applicable | AED 15,000 |
| Bilateral or multilateral APA | Not offered | Still not offered; framework remains unilateral only |
| Tax Residency Certificates, tax agent registration, private clarifications, and other pre-existing services | Governed by Cabinet Decision No. 65 of 2020 as amended | Unchanged by Cabinet Decision No. 174 of 2025 |
What Is a Unilateral Advance Pricing Agreement (APA) in the UAE?
An Advance Pricing Agreement is a forward-looking arrangement between a taxpayer and a tax authority. Instead of waiting for an audit to test whether related-party pricing meets the arm’s length principle, the taxpayer and the FTA agree in advance on the transfer pricing methodology that will apply to specified transactions over a defined period.
A unilateral APA is one where a single tax authority, the FTA, agrees the transfer pricing approach with the taxpayer for UAE tax purposes only. Bilateral and multilateral APAs, which involve agreement across two or more tax jurisdictions, are not yet available under the current UAE framework. The fee provisions introduced by Cabinet Decision No. 174 of 2025 apply only to unilateral APAs.
The underlying arm’s length principle is set out in Federal Decree-Law No. 47 of 2022 on Corporate Tax and is aligned with OECD Transfer Pricing Guidelines. A UAE entity is generally treated as a related party where there is common ownership or control of 50 percent or more.
How to Apply for a Unilateral APA: Step-by-Step Process
While the FTA has not published a single consolidated procedural manual for APA applications, the process follows the general structure used for advance pricing arrangements internationally, adapted to UAE requirements:
- Pre-filing assessment. The business reviews its related-party transactions to confirm they cross the thresholds that make an APA worthwhile, and identifies the specific transactions the APA should cover.
- Preparation of supporting analysis. This includes a functional analysis of the parties involved, a benchmarking study to support the proposed arm’s length methodology, and a description of the transaction structure.
- Submission of the formal request. The taxpayer submits the APA application to the FTA along with the AED 30,000 first-submission fee and the supporting documentation.
- FTA review and evaluation. The FTA examines the functional analysis, benchmarking study, and proposed methodology, and may request further information or clarification.
- Agreement and monitoring. Once the FTA and taxpayer reach agreement, the APA sets the accepted transfer pricing methodology for the agreed period. The taxpayer must then apply that methodology consistently and retain documentation to demonstrate compliance.
- Renewal or amendment. Before the agreed period expires, or if circumstances change materially, the taxpayer can apply to renew or amend the APA for the AED 15,000 fee.
Businesses that most commonly consider this route include groups that already exceed the Local File threshold of AED 4,000,000 in aggregate related-party transactions under Ministerial Decision No. 97 of 2023, multinational groups with recurring transfer pricing audit exposure, and Qualifying Free Zone Persons for whom a transfer pricing breach would put their 0 percent tax status at risk.
Must check: Benchmarking Analysis Services in UAE
Common Misconceptions About UAE APA Fees and Tax Certainty
Several assumptions about the new APA fee framework are worth correcting before a business decides to apply:
- “An APA guarantees a lower tax bill.” An APA does not reduce a company’s tax liability. It confirms the transfer pricing methodology the FTA will accept, which changes the risk profile of an audit, not the substantive tax rate.
- “The AED 30,000 fee guarantees approval.” The fee covers the cost of processing and evaluating the application. It does not guarantee the FTA will accept the proposed methodology.
- “Bilateral APAs are now available.” As of the current framework, only unilateral APAs are covered by the fee schedule under Cabinet Decision No. 174 of 2025. Bilateral and multilateral options remain undeveloped.
- “The new fees apply to all FTA services.” The AED 30,000 and AED 15,000 fees apply only to APA applications and renewals. Fees for tax residency certificates, tax agent registration, and other existing services are unchanged.
- “Small businesses need an APA too.” An APA is most relevant for groups with material related-party transaction volumes, typically those already at or above the Local File threshold. Businesses well below that threshold are unlikely to find the cost and documentation burden proportionate.
Legal Framework Governing FTA Service Fees and APA Rules
FTA service fees, including the new APA-related charges, sit within a layered legal structure of Federal Decree-Laws and Cabinet Decisions:
- Federal Law No. 1 of 1972 on the competencies of ministries, which underpins the federal government’s regulatory authority, including tax administration.
- Federal Decree-Law No. 13 of 2016, which establishes the Federal Tax Authority and its power to administer federal tax laws and services.
- Federal Decree-Law No. 28 of 2021 on Tax Procedures, as amended by Federal Decree-Law No. 17 of 2025 (effective 1 January 2026), which governs the procedural relationship between taxpayers and the FTA, including the standard 5-year FTA audit window and updated voluntary disclosure conditions.
- Federal Decree-Law No. 7 of 2017 on Excise Tax and Federal Decree-Law No. 8 of 2017 on VAT, which cover the substantive tax regimes that overlap with routine FTA clarification and compliance services.
- Federal Decree-Law No. 47 of 2022 on Corporate Tax, which incorporates the transfer pricing regime and the arm’s length principle that APAs are designed to give certainty over.
- Federal Decree-Law No. 26 of 2019 on Public Finance, which sets the broader public finance rules affecting government revenue mechanisms.
On top of this legislative base, Cabinet Decision No. 65 of 2020 set out the original FTA service fee structure, Cabinet Decisions No. 7 and No. 111 of 2023 amended it, and Cabinet Decision No. 174 of 2025 adds the APA fee categories. These decisions are published on the UAE Legislation portal and the FTA’s own legislation page, which carry the consolidated texts and unofficial translations.
See also: International Tax Advisor in Dubai, UAE
What This Means for UAE Businesses and Tax Professionals in 2026
Cabinet Decision No. 174 of 2025 is a narrow but meaningful change. It does not alter the substance of the arm’s length principle or the underlying Corporate Tax rules. What it does is put a price on formal tax certainty: a business that wants the FTA’s advance agreement on its transfer pricing methodology now has a defined cost and, implicitly, a formal channel to request it.
For groups already close to or above the transfer pricing documentation thresholds, this is a reason to revisit whether an APA is worth pursuing for their highest-risk related-party transactions. For smaller businesses without material related-party dealings, the change has limited practical effect beyond general awareness that the option now exists.
Tax and accounting teams preparing for 2026 should budget for the new fees where an APA filing is under consideration, keep benchmarking studies and functional analyses current in case an application is submitted, and monitor the FTA’s official fee schedule for any further updates, since the underlying Cabinet Decision framework has been amended multiple times since 2020.
How Farahat & Co. Can Help
Farahat & Co. supports UAE businesses with transfer pricing documentation, benchmarking studies, and advisory on FTA compliance processes, including preparing the functional analysis and supporting documentation an APA application requires.
Contact Farahat & Co. today to discuss your UAE FTA service fees and APA requirements.
Need Expert Advice?
Contact the team at Farahat & Co. for professional support and expert insights for businesses operating in the UAE.
