Master file and local file

 In addition to the submission of a general transfer pricing disclosure form, Taxable Persons need to maintain a ‘master file’ and a ‘local file’ if their Revenue in the relevant Tax Period is AED 200,000,000 or more, or they are part of a Multinational Enterprise Group (MNE) with total consolidated group revenue over or equal to AED 3,150,000,000 in the preceding Financial Year.227

Generally, a master file is a ‘blueprint’ of a group’s activity, containing information on its economic activities in different jurisdictions and its overall transfer pricing policy.

On the other hand, a local file contains more detail than a master file, specifically in relation to Related Party and Connected Persons transactions undertaken by group members. The purpose is to provide functional and economic analysis to support the arm’s length basis of its transactions

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