20 August 2026 · Documentation
UAE Master File & Local File Requirements
A UAE business must maintain a transfer pricing Master File and Local File when it has standalone revenue of at least AED 200 million, or is part of a multinational group with consolidated revenue of at least AED 3.15 billion, for any financial year in which it has related-party or connected-person transactions. The files are not filed with the return — you maintain them internally and submit them to the FTA within 30 days of a written request, which is why they need to be complete and current before you file, not assembled afterwards. Very large multinational groups may also carry a separate Country-by-Country Reporting obligation layered on top of the Master and Local File requirement.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
The documentation thresholds
Master File and Local File obligations are threshold-based, tested every financial year against your own revenue and, where relevant, your group's consolidated revenue. Crossing a threshold in one year does not necessarily mean you stay in scope forever — the test is applied afresh each year, so a business can move in and out of the obligation as it grows or its group structure changes. The Disclosure Form, by contrast, can apply well below either threshold, so a business can face reporting duties long before it ever needs a full Master and Local File.
- Standalone revenue of AED 200 million or more.
- Membership of an MNE group with AED 3.15 billion+ consolidated revenue.
- Tested separately for each financial year, not a one-time trigger.
- Files are maintained, not filed with the return.
- The FTA can demand them within 30 days of a request.
- The Disclosure Form threshold sits well below either figure.
Master File vs Local File
The two files serve different purposes and, read together, tell the FTA how your pricing was actually set rather than just what it ended up being. The Master File paints the group picture — structure, value drivers, financing and where intangibles sit — while the Local File narrows in on the UAE entity's own transactions and the benchmarking behind each one. Consistency between the two, and between both files and the CT return and Disclosure Form, is what a reviewer checks first.
- Master File: the group's global structure, value drivers and IP.
- Local File: the UAE entity's specific related-party transactions.
- Benchmarking studies supporting each material transaction.
- Consistency between the files and the CT return.
- Written intercompany agreements referenced, not just journal entries.
- Financial statements the figures can be traced back to.
When to prepare, not scramble
The 30-day clock only starts once the FTA asks — but a Master File and Local File cannot realistically be built from scratch in that window. The practical approach is to treat documentation as part of the annual corporate tax filing cycle: finalise the transactions and benchmarking alongside the return, so the files exist and are current well before any request could land. Businesses that wait until a request arrives are almost always assembling the study under time pressure rather than reviewing one that already exists.
- Build documentation alongside the annual CT filing cycle, not after.
- A 30-day window is not enough time to start from zero.
- Refresh benchmarking each year the underlying facts change.
- Keep a single owner responsible for the files staying current.
What happens inside the 30-day window
When the FTA issues a request, it is typically part of a wider review of your corporate tax position, so the Master File and Local File rarely arrive in isolation from other questions about related-party dealings. Missing the deadline, or submitting files that do not reconcile to your Disclosure Form and financial statements, tends to escalate the review rather than close it. For groups large enough to also carry Country-by-Country Reporting duties, that filing sits alongside the Master and Local File as a separate, group-level obligation.
- Requests usually arrive as part of a wider corporate tax review.
- Late or incomplete submission tends to escalate the enquiry.
- Files must reconcile to the Disclosure Form and financial statements.
- Country-by-Country Reporting is a separate, group-level obligation for the largest groups.
Related guides
Frequently Asked Questions
For groups working out whether they must document, and what to have ready before a request arrives.
Do I have to file the Master and Local File with my return?
No. You maintain them internally and only submit to the FTA within 30 days if requested, so they must already be prepared and current by the time you file your return, not built afterwards.
What are the thresholds?
AED 200 million standalone revenue, or being part of a multinational group with consolidated revenue of AED 3.15 billion or more. Both are tested for the relevant financial year, not fixed permanently once crossed.
What is the difference between the two files?
The Master File covers the whole group's structure, value drivers and financing; the Local File focuses in detail on the UAE entity's own related-party transactions and the benchmarking behind them.
What happens if I can't produce the files within 30 days?
Late or incomplete submission tends to extend and escalate the FTA's review rather than close it, and can expose the business to administrative penalties on top of any transfer pricing adjustment. This is why the files need to exist before the request lands.
Does the threshold apply per company or per group?
The AED 200 million test looks at the individual UAE taxable person's own revenue; the AED 3.15 billion test looks at the consolidated revenue of the wider multinational group it belongs to. Either one being met brings the obligation into scope.
Do free zone entities still need Master and Local Files?
Yes. Qualifying Free Zone Person status changes the tax rate on qualifying income, not the documentation obligation — a free zone entity that crosses either threshold and has related-party transactions is in scope the same as a mainland one.
Is there a Country-by-Country Reporting requirement too?
For the largest multinational groups, yes — Country-by-Country Reporting is a separate, group-level filing that can sit alongside the Master and Local File requirement. It is assessed independently, so being out of scope for one does not automatically mean you are out of scope for the other.
Can Exiloz prepare our documentation?
Yes. We build a Master File, Local File and the benchmarking studies behind them so they are ready to submit within the FTA's 30-day window, and we keep them current as your transactions change.
Be ready before the FTA asks
Exiloz prepares audit-ready Master and Local Files, refreshed each filing cycle, so a 30-day FTA request is routine paperwork rather than an emergency.