Transfer pricing documentation: master and local file
- Applies
- FY2024 onwards
- Reviewed
- Rule
- UAE-CT-TPDOC-2024.1
Who must keep a UAE master file and local file?
A taxpayer with revenue of AED 200 million or more, or in a group with AED 3.15 billion or more. Both are due 30 days after a request.
Per Federal Decree-Law No. 47 of 2022, Article 55, Transfer Pricing Documentation
A Taxable Person must maintain both a master file and a local file, in the form the Authority prescribes, where its Revenue in the Tax Period is AED 200 million or more, or where at any time in the period it is a Constituent Company of a Multinational Enterprises Group with consolidated Revenue of AED 3.15 billion or more. The files must be submitted within 30 days of a request, or any later date the Authority directs; and any Taxable Person must provide information supporting the arm's length nature of its Related Party and Connected Person transactions within the same window on request.
The record-keeping obligation behind the arm's length standard. The master and local file requirement is conditional on the Minister's conditions; the obligation to support the arm's length nature of transactions on request is not.
Two obligations, one conditional and one not
55(2) and MD 97 of 2023 Article 2(1) — who keeps the files
- (a) A Constituent Company, at any time in the Tax Period, of a Multinational Enterprises Group with total consolidated group Revenue of AED 3,150,000,000 or more; or
- (b) A Taxable Person whose own Revenue in the Tax Period is AED 200,000,000 or more
What the local file covers — MD 97 of 2023 Article 2(2) and (3)
- Included: transactions with Related Parties and Connected Persons that are Non-Resident, Exempt Persons, Resident Persons that elected Small Business Relief, or Resident Persons taxed at a different rate (for example a Qualifying Free Zone Person)
- Excluded: other Resident Persons; natural persons and partners in an Unincorporated Partnership acting as if independent; and a UAE Permanent Establishment taxed at the same rate
- Acting 'as if independent' means in the ordinary course of Business, and not exclusively or almost exclusively with each other
Both files or neither
The article says "both a master file and a local file". Maintaining one of the two is not partial compliance with the obligation, so the rule names which is missing rather than reporting a proportion.
55(4) — the wider obligation, which is not conditional
On request, a Taxable Person must provide the Authority with ANY information supporting the arm's length nature of its transactions with Related Parties and Connected Persons — whether or not the Minister's conditions for the master and local file are met. A reader below those conditions is not free of Article 55, and this is the part that surprises them.
55(3) and 55(4) — the window
The published number of days following a request by the Authority, or by any such other later date as the Authority directs. The rule reports the published figure and says the Authority may direct a later date.
Order of testing
- 1
Inputs requiring your determination
Any input a person must decide and has not decided stops the computation. The two files are asked about only where the obligation to keep them arises.
- 2
The conditions prescribed by the Minister
Where the transactions do not meet them, no master and local file obligation arises under Article 55(2) — and the result says the Article 55(4) obligation and the Article 55(1) disclosure may still apply.
- 3
Both a master file and a local file
Where the conditions are met, both must be maintained. The result names whichever is missing, and states the submission window either way.
Examples
Illustrative scenarios — ours, not the authority’s — each computed live by this rule. Change any fact and the outcome is the rule’s, not a hand-written answer.
Both files maintained
A company with Revenue of AED 250 million keeps both files and can support its prices.
Computed
The Article 55(2) obligation is met as computed: the Minister's conditions apply because its Revenue of AED 250,000,000 is at least AED 200,000,000, and both a master file and a local file are maintained, in the form the Authority prescribes. Either must be submitted within 30 days of a request by the Authority, or by any later date the Authority directs. Separately, Article 55(4) requires any information supporting the arm's length nature of the transactions to be provided within 30 days of a request, or by any later date the Authority directs, and you have indicated it can be. Whether the files satisfy the Authority's prescribed form is not something this rule tests and requires your determination.
Workings
- Revenue of the Taxable Personas supplied
- AED 250,000,000
- Revenue conditionMD 97 of 2023 Article 2(1)(b) — published value for FY2026, 'or more'
- AED 200,000,000
- Consolidated Revenue of the MNE Groupas supplied; nil if none
- AED 0
- Group revenue conditionMD 97 of 2023 Article 2(1)(a) — published value for FY2026, 'or more'
- AED 3,150,000,000
- Days to respond to a requestArticles 55(3) and 55(4) — published value for FY2026, or any later date the Authority directs
- 30
Decided by the both a master file and a local file
A small subsidiary of a large group, local file only
A UAE subsidiary with Revenue of AED 20 million in a group with AED 5 billion of consolidated Revenue keeps a local file but no master file.
Computed
The Article 55(2) obligation is not met as computed: where the Minister's conditions are met — here because it is in a Multinational Enterprises Group with consolidated Revenue of AED 5,000,000,000, at least AED 3,150,000,000 — the Taxable Person must maintain both a master file and a local file in the form the Authority prescribes, and you have indicated a master file is not maintained. Either must be submitted within 30 days of a request by the Authority, or by any later date the Authority directs. Separately, Article 55(4) requires any information supporting the arm's length nature of the transactions to be provided within 30 days of a request, or by any later date the Authority directs, and you have indicated it can be.
Workings
- Revenue of the Taxable Personas supplied
- AED 20,000,000
- Revenue conditionMD 97 of 2023 Article 2(1)(b) — published value for FY2026, 'or more'
- AED 200,000,000
- Consolidated Revenue of the MNE Groupas supplied; nil if none
- AED 5,000,000,000
- Group revenue conditionMD 97 of 2023 Article 2(1)(a) — published value for FY2026, 'or more'
- AED 3,150,000,000
- Days to respond to a requestArticles 55(3) and 55(4) — published value for FY2026, or any later date the Authority directs
- 30
Decided by the both a master file and a local file
Below both conditions, but able to support the transactions
A standalone company with Revenue of AED 60 million.
Computed
No master and local file obligation arises under Article 55(2) as computed: Ministerial Decision No. 97 of 2023 requires them where Revenue is AED 200,000,000 or more, or where the Taxable Person is in a Multinational Enterprises Group with consolidated Revenue of AED 3,150,000,000 or more, and neither is met on the figures you supplied. Separately, Article 55(4) requires any information supporting the arm's length nature of the transactions to be provided within 30 days of a request, or by any later date the Authority directs, and you have indicated it can be. A disclosure with the Tax Return may still be required under Article 55(1).
Workings
- Revenue of the Taxable Personas supplied
- AED 60,000,000
- Revenue conditionMD 97 of 2023 Article 2(1)(b) — published value for FY2026, 'or more'
- AED 200,000,000
- Consolidated Revenue of the MNE Groupas supplied; nil if none
- AED 0
- Group revenue conditionMD 97 of 2023 Article 2(1)(a) — published value for FY2026, 'or more'
- AED 3,150,000,000
- Days to respond to a requestArticles 55(3) and 55(4) — published value for FY2026, or any later date the Authority directs
- 30
Decided by the conditions prescribed by the minister
Below both conditions, and unable to support the transactions
The same company, with no benchmarking or other support for its intra-group prices.
Computed
No master and local file obligation arises under Article 55(2) as computed: Ministerial Decision No. 97 of 2023 requires them where Revenue is AED 200,000,000 or more, or where the Taxable Person is in a Multinational Enterprises Group with consolidated Revenue of AED 3,150,000,000 or more, and neither is met on the figures you supplied. Separately, Article 55(4) requires any information supporting the arm's length nature of the transactions to be provided within 30 days of a request, or by any later date the Authority directs. You have indicated it cannot be, and that obligation applies whether or not the master and local file conditions are met. A disclosure with the Tax Return may still be required under Article 55(1).
Workings
- Revenue of the Taxable Personas supplied
- AED 60,000,000
- Revenue conditionMD 97 of 2023 Article 2(1)(b) — published value for FY2026, 'or more'
- AED 200,000,000
- Consolidated Revenue of the MNE Groupas supplied; nil if none
- AED 0
- Group revenue conditionMD 97 of 2023 Article 2(1)(a) — published value for FY2026, 'or more'
- AED 3,150,000,000
- Days to respond to a requestArticles 55(3) and 55(4) — published value for FY2026, or any later date the Authority directs
- 30
Decided by the conditions prescribed by the minister
Try it
Supply the facts and this rule computes the outcome in your browser, live. Leave a determination undecided and it blocks the result — it is never read as a no.
Not computed yet
3 inputs still need your determination:
- What is the Taxable Person's Revenue in the Tax Period?
- At any time in the period, was the Taxable Person a Constituent Company of a Multinational Enterprises Group? If so, what is the group's total consolidated Revenue for the period — and nil if not.
- Can the Taxable Person provide the Authority, on request, with information supporting the arm's length nature of its transactions with Related Parties and Connected Persons? Article 55(4) applies whether or not the master and local file conditions are met.
Computed in your browser from the figures you supply. Nothing is sent anywhere, and the result is a computation against a rule — reference, not tax advice.
Thresholds
- uae.tp_documentation_response_days
- count 30 · reviewed 2026-09-28 · source
- uae.tp_documentation_revenue_threshold
- AED 200,000,000 · reviewed 2026-09-28 · source
- uae.tp_documentation_mne_group_revenue_threshold
- AED 3,150,000,000 · reviewed 2026-09-28 · source
Threshold values are published separately from the rule and carried with a citation. Where none has been published for the period being computed, the rule reports that rather than applying a default.
Sources
Federal Decree-Law No. 47 of 2022, Article 55 — Transfer Pricing Documentation
The article this rule encodes; Clauses 2 to 4
https://mof.gov.ae/wp-content/uploads/2022/12/Federal-Decree-Law-No.-47-of-2022-EN.pdfMinisterial Decision No. 97 of 2023 — Transfer Pricing Documentation
The conditions for the master and local file, and what the local file covers
https://mof.gov.ae/wp-content/uploads/2023/05/Ministerial-Decision-No.-97-of-2023-for-the-Purposes-of-Federal-Decree-Law-No.-47-of-2022.pdfFTA — Transfer Pricing Guide (CTGTP1)
The Authority's guidance on the files and their content
https://tax.gov.ae/Datafolder/Files/Pdf/2023/Transfer%20Pricing%20Guide%20-%20EN%20-%2023%2010%202023.pdf