The group-level context for a UAE entity’s transactions

The Master File presents the multinational group in its entirety — its organisational and legal structure, its business lines, its intangibles, its intra-group financing, and its global transfer pricing policies. It gives the FTA the group-wide context within which a UAE entity's related party transactions are assessed, and it is often where any inconsistency between the group's narrative and the local position first becomes apparent.

The Master File is group-level; the Local File is entity-level. The Master File describes the multinational group as a whole, while the Local File details one UAE entity's specific related party transactions and the arm's length analysis supporting them. The two are read together — the group-wide context and the local position, told as one consistent account.

Under Article 55, read with Ministerial Decision No. 97 of 2023, a Master File is required where a taxable person belongs to a multinational group with consolidated revenue of AED 3.15 billion or more. Because the obligation follows MNE group membership rather than entity size alone, a purely domestic UAE group can owe a Local File without a Master File, even where it meets the AED 200 million Local File threshold.

That same logic carries an exemption: a UAE-headquartered group comprising only UAE entities — with no foreign constituent entity or permanent establishment — may not need to maintain a Master File at all, even where it must maintain a Local File. This reflects the exception for UAE-headquartered groups that are not multinational enterprise groups; the Local File obligation itself remains subject to the applicable thresholds.

Our approach

  • We describe the group's organisational structure and business lines.
  • We document the group's intangibles and how they are developed, owned and exploited.
  • We set out the group's intra-group financing and transfer pricing policies.
  • We align the Master File with the Local File and CbCR into one coherent set.

The UAE position

  • Obligation — Article 55 and Ministerial Decision No. 97 of 2023 — triggered by MNE group membership at the AED 3.15 billion threshold
  • Related documents — Local File; Country-by-Country Reporting