The UAE revenue threshold is relevant
The taxable person's revenue meets or approaches the applicable UAE threshold for maintaining formal files.
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UAE Transfer Pricing / Formal Files
Prepare formal Transfer Pricing filesthat reconcile to the business and return.
We assess whether the UAE documentation requirements apply, define the covered transaction population and prepare or localise the relevant file. The analysis is tied to agreements, interviews, benchmarks, financial statements and the Corporate Tax return rather than assembled as a standalone narrative.
Threshold-testedEntity and multinational-group conditions assessed
Transaction-ledMaterial controlled arrangements documented
FTA-ready structureEvidence and financial schedules are indexed
When this service fits
Choose it for a defined business need.
Use this service when the formal-documentation position must be established or the required files need to be prepared, updated or localised for the UAE entity.
The entity belongs to a large MNE group
The consolidated multinational-group revenue condition may trigger the documentation requirement.
A global file needs UAE localisation
Group material exists but the UAE transaction population, local functions and financial results are not properly reflected.
An FTA request could arrive
Management needs a complete, internally reviewed file and evidence index that can be retrieved promptly.
How the engagement moves
Four stages. A defined output at every stage.
Thresholds determine whether formal files are mandatory. The content itself is then built around the UAE entity's actual controlled transactions and financial results.
01Stage 01
Confirm the filing obligation
Test the taxable-person revenue and multinational-group conditions, entity status and any relevant exception using current information.
Stage outputFormal-file obligation conclusion
02Stage 02
Define the covered population
Map material transactions, counterparties, agreements, methods, benchmarks and the financial schedules needed for the UAE Local File.
Stage outputCovered-transaction map
03Stage 03
Draft and challenge
Prepare the entity and transaction analyses, conduct interviews, resolve gaps and check consistency with group material and actual conduct.
Stage outputReviewed draft file
04Stage 04
Reconcile and finalise
Tie transaction values and tested results to the accounts and return, index the evidence and document unresolved dependencies.
Stage outputReconciled final documentation pack
Defined deliverables
What management receives.
The deliverables are confirmed after the threshold and group-document review. A Master File is not automatically added where the UAE rules do not require one.
Documentation-obligation memo
Threshold calculations, group-status analysis, relevant exceptions and the required document set for the period.
UAE Local File
Local entity, controlled transactions, functional analysis, method, economic support and financial information in a coherent file.
Master File support
Preparation, review or UAE consistency support where a Master File is applicable and the required group information is available.
Financial and evidence index
Transaction reconciliations, source references, benchmark links, open items and the records supporting each material section.
Formal documentation thresholds
Thresholds determine the formal files—not the arm's-length obligation.
Under the published UAE framework, a Master File and Local File are required for an entity in a multinational group with consolidated group revenue of at least AED 3.15 billion, or a taxable person with revenue of at least AED 200 million, subject to the detailed rules and entity facts.
Federal Tax Authority — Transfer Pricing Guide (CTGTP1)Taxable-person revenue test
The UAE revenue condition is tested for the relevant tax period using the required basis.
MNE consolidated-revenue test
The multinational-group condition can apply even where the UAE entity's own revenue is below AED 200 million.
Response expectation
The FTA guide states the files should be provided within 30 days of request, or a longer period agreed with the FTA.
Master File distinction
A UAE-headquartered group that is not an MNE does not prepare a Master File solely under the domestic-group position, while the Local File test may still apply.
Records to begin
Start with the evidence that creates the position.
The information request is issued by file section and transaction, which makes missing group or local records visible early.
- UAE entity and multinational-group revenue evidence
- Legal and operational group structure
- Group Master File or global documentation
- UAE entity financial statements and trial balance
- Controlled-transaction ledgers and reconciliations
- Intercompany agreements and invoice samples
- Functional interviews and process documentation
- Policies, benchmarks and Corporate Tax return schedules
Questions before you engage
Clear answers about this scope.
These answers explain the service boundary. The final treatment and engagement plan depend on the entity, period, records and current UAE requirements.
Does every UAE company need a Local File and Master File?
No. The formal requirement depends on the specified revenue and multinational-group conditions. Reasonable Transfer Pricing records can still be required below those thresholds.
Are the files submitted with the Corporate Tax return?
They are generally maintained rather than routinely attached to the return, but must be available if requested by the FTA. Return disclosures are a separate compliance step.
Can a global Local File be used for the UAE?
It can provide a starting point, but the UAE file should reflect the local entity, relevant UAE rules, actual transaction values, functions and return position.
What if a benchmarking study is missing?
We identify the gap during scoping. Where reliable economic support is required, a separate benchmarking workstream can be completed and referenced in the file.
Can you update an existing file?
Yes. We first compare it with the current entity, transaction population, financial period and supporting evidence, then scope only the sections that need revision.
Related services
Move to the service that matches the next requirement.
Each page has its own defined purpose. Use the current service for the work described here, or choose another service when the business need changes.
Contact Us
Assess the File Requirement Do not wait for a 30-day request to assemble the file.
Share the UAE entity revenue, group revenue, tax period and any existing group documentation so we can assess the file requirement.