Shaping Certainty in a New Tax Landscape: Reflections on the UAE’s APA Programme

The UAE's introduction of an Advance Pricing Agreement ('APA') framework marks a significant milestone in the country's corporate tax evolution. With the release of the Federal Tax Authority's Corporate Tax Guide on Advance Pricing Agreements (CTGAPA1), taxpayers now have a structured mechanism to obtain prospective certainty on transfer pricing outcomes. Beginning with domestic unilateral APAs from December 2025 and cross‑border applications expected in 2026, the framework arrives at a pivotal moment, offering businesses a forward‑looking tool for risk management, planning, and governance.