If your business is part of a larger corporate group operating in the UAE, the master file is no longer a theoretical concern. It is a formal transfer pricing document that the Federal Tax Authority (FTA) can request under the Corporate Tax regime, and one that businesses above certain thresholds are legally required to hold. The practical question most finance teams face is not whether the master file matters, but who prepares it and what professional services actually exist to get it right. This guide answers that directly.
Below is a plain overview of what a master file is, who needs one in the UAE, what it must contain, and the specific master file services available to UAE businesses, including how BCL Globiz delivers them.
What is a transfer pricing master file?
The master file is one of the three tiers of transfer pricing documentation set out under the OECD BEPS Action 13 framework, which the UAE has adopted. The three tiers are the master file, the local file, and the Country-by-Country Report (CbCR). While the local file focuses on a specific UAE entity and its individual related-party transactions, the master file gives the tax authority a high-level, group-wide view of a multinational group’s global business, its structure, its intangibles, its financing arrangements, and its overall transfer pricing policies.
In short, the local file explains one entity in detail, and the master file explains how that entity fits inside the wider group. The FTA reads the two together to judge whether controlled transactions are priced on an arm’s length basis.
The legal basis in the UAE
The requirement flows from Article 55 of Federal Decree-Law No. 47 of 2022 (the UAE Corporate Tax Law), which requires qualifying taxable persons to maintain a master file and a local file as prescribed by the FTA. Ministerial Decision No. 97 of 2023, issued by the Ministry of Finance and effective for tax periods starting on or after 1 June 2023, sets out the specific thresholds and conditions. Both files must be submitted to the FTA within 30 days of a request.
Who needs a master file in the UAE?
Under Ministerial Decision No. 97 of 2023, a taxable person must maintain both a master file and a local file if it meets either of the following conditions in the relevant tax period:
Group threshold: the business is a constituent entity of a multinational enterprise (MNE) group with total consolidated group revenue of AED 3.15 billion or more; or
Entity threshold: the taxable person’s own revenue is AED 200 million or more in the relevant tax period.
Because the master file describes a multinational group as a whole, it is most relevant to businesses that form part of an MNE group. A standalone business with only domestic operations still needs to consider its position carefully, which is exactly why an applicability assessment is usually the first service a business engages. It is also worth noting that even businesses below these thresholds are not exempt from the underlying arm’s length principle. Every UAE taxpayer with related-party transactions must still be able to justify its pricing if the FTA asks, and entities claiming Small Business Relief have separate treatment for documentation purposes.
What must a UAE master file contain?
Following the OECD standard adopted by the UAE, a master file is built around five broad categories of information about the group:
Organizational structure: A chart showing the group’s legal and ownership structure and the geographic location of its operating entities.
Description of the business: An overview of the group’s business or businesses, including key profit drivers, the supply chain for major products and services, and important service arrangements between group members.
Intangibles: The group’s overall strategy for developing, owning and exploiting intangibles, a list of important intangibles and which entities legally own them, and key agreements such as cost contribution arrangements and licence agreements.
Intercompany financial activities: How the group is financed, including important financing arrangements with lenders, and the entities that perform central financing functions.
Financial and tax positions: The group’s consolidated financial statements and details of existing unilateral advance pricing agreements and other tax rulings relating to the allocation of income.
Assembling this information accurately, and keeping it consistent with the local file and any CbCR, is where specialist master file services add the most value.
The transfer pricing master file services available in the UAE
Professional firms in the UAE offer master file work as a set of connected services rather than a single deliverable. The main services available are as follows.
Applicability and threshold assessment: Before any drafting begins, advisers assess whether the business actually crosses the AED 3.15 billion group threshold or the AED 200 million entity threshold, and confirm whether it is a constituent entity of an MNE group. This prevents both over-compliance and missed obligations.
Master file preparation and drafting: The core service is preparing the master file itself, structured around the five OECD content categories and tailored to the group’s facts, so that it is ready to submit within the FTA’s 30-day window.
Group structure and value chain mapping: Advisers document the group’s legal and organizational structure and map the supply chain and key profit drivers, which forms the backbone of the master file narrative.
Intangibles and IP documentation: Because intangibles are a common area of tax authority scrutiny, firms document the group’s IP strategy, legal ownership, and the intercompany agreements attached to those intangibles.
Intercompany financing documentation: Group financing arrangements, treasury functions and related-party loans are documented and, where needed, tested against the arm’s length principle.
Benchmarking and comparability support: Although benchmarking studies primarily support the local file, they underpin the pricing policies described in the master file. Firms run comparability studies using recognised commercial databases to build defensible positions.
Master file and local file consistency alignmen:. A frequent audit risk is inconsistency between the group-level master file and the entity-level local file. A dedicated alignment service checks that the two documents tell the same story.
CbCR coordination: For large MNE groups, advisers coordinate the master file with Country-by-Country Reporting obligations so that group-wide data is consistent across all three documentation tiers.
Master file review and gap analysis: For groups that already hold a master file, perhaps prepared by an overseas parent, firms review it against UAE requirements and close any gaps rather than rebuilding from scratch.
Contemporaneous updates and annual refresh: Transfer pricing documentation is expected to be contemporaneous, so firms refresh the master file each tax period to reflect changes in structure, transactions and financials.
FTA audit support and 30-day readiness: If the FTA issues a documentation request, advisers help respond within the 30-day deadline and provide audit defence, including responding to queries and supporting any adjustments discussion.
How BCL Globiz delivers master file services
BCL Globiz Accounting & Consulting L.L.C., the flagship firm of the BCL Group, provides master file and wider transfer pricing services to businesses across the UAE. The firm prepares master files, local files and transfer pricing disclosure forms in line with UAE regulations and OECD guidelines, and supports clients through the full compliance cycle from applicability assessment to FTA audit response.
The credentials behind that offering include more than 35 years of experience and a team of over 300 professionals globally, including Chartered Accountants and CPAs. BCL Globiz reports serving more than 1,000 UAE businesses across over 30 industries, with a client renewal rate of around 94 percent, and maintains a presence spanning Dubai, India and beyond.
For benchmarking and comparability analysis that supports the pricing policies described in the master file, BCL Globiz uses recognised commercial databases such as S&P Capital IQ, Orbis, TP Catalyst, Amadeus and Bloomberg. This combination of qualified specialists and tier-one data is what allows the firm to build master files that stand up to FTA scrutiny.
Deadlines, retention and why timing matters
The master file does not have to be filed with the FTA automatically each year. Instead, it must be produced within 30 days of an FTA request, and supporting documentation is generally expected to be retained for several years in line with UAE record-keeping rules. The practical problem is that a compliant master file can take weeks to prepare properly, while the FTA gives only 30 days once it asks. Preparing the master file in advance, on a contemporaneous basis, is therefore the safer approach, and is the main reason businesses engage these services before a request ever arrives.
The bottom line
Transfer pricing master file services in the UAE run well beyond simple document drafting. They cover applicability assessment, group and value chain mapping, intangibles and financing documentation, benchmarking support, consistency alignment with the local file and CbCR, periodic refreshes, and full FTA audit support. Businesses that cross the AED 3.15 billion group threshold or the AED 200 million entity threshold should treat the master file as a live compliance obligation rather than a one-off task.
For UAE businesses that want an FTA-ready master file prepared by qualified specialists, BCL Globiz offers end-to-end transfer pricing support aligned with Ministerial Decision No. 97 of 2023 and OECD guidelines.
Learn more or speak to a transfer pricing specialist at bcl.ae or email info@bcl.ae.
