Master File Maintenance: MNE Transfer Pricing Documentation

Aligning global business structures with UAE Corporate Tax Laws and BEPS Action 13 standards.

Comply with OECD BEPS Action 13 by documenting your MNE group’s global structure and financial blueprint. G12 prepares defensible Master Files that withstand FTA scrutiny and mitigate cross-border transfer pricing risks.

Regulatory Context

Adherence to International Reporting Standards

Transfer Pricing documentation is no longer optional for qualifying entities. The Master File provides tax authorities with a standardized overview of your organizational footprint, intangibles, and intercompany financial activities. Its primary function is to allow the FTA to assess high-level transfer pricing risk and ensure profit allocation matches economic substance.
G12 conducts a comprehensive gap analysis between your current group documentation and the specific requirements of OECD BEPS Action 13 and UAE Transfer Pricing regulations. We ensure that your global narrative is consistent with local entity filings, eliminating discrepancies that trigger audits.

Eligibility Criteria

Statutory Applicability Thresholds

UAE Corporate Tax Law and Ministerial Decision No. 97 of 2023 define strict criteria for Master File maintenance. Entities meeting the following conditions must prepare and maintain this documentation:

Revenue Threshold: Taxable Persons generating revenues of AED 200 million or more in the relevant tax period.
MNE Group Threshold: Entities that are part of a Multinational Enterprise Group with a total consolidated group revenue exceeding AED 3.15 billion in the preceding financial year.

Compliance extends to associated enterprises and subsidiaries engaging in material related-party transactions. G12’s tax advisors verify your eligibility status based on quantitative revenue analysis and group structure assessments

Audit Completed

Consultation

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Financial Experts

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Technical Execution of Group Reporting

Data consistency across jurisdictions is critical. A Master File that contradicts a Local File or Country-by-Country Report (CbCR) exposes the group to immediate regulatory penalties. G12 applies a forensic approach to data compilation, ensuring your documentation reflects the Arm’s Length Principle.

Our Operational Framework Includes:

Global Value Chain Mapping: Detailed articulation of the group’s supply chain, identifying where value is generated versus where profits are booked.
DEMPE Analysis: Identification of entities responsible for the Development, Enhancement, Maintenance, Protection, and Exploitation of intangibles to justify royalty flows.
Intercompany Financials: Documentation of group financing arrangements, including transfer pricing policies for R&D and headquarters services.
Jurisdictional Alignment: Ensuring the Master File satisfies the specific filing requirements of the UAE while remaining compatible with regulations in other countries where the group operates.

Mitigating Cross-Border Tax Risks

Managing a Master File requires more than data entry; it requires a strategic understanding of international tax law. G12 functions as your technical partner, leveraging data-driven methodologies to secure your tax position.

Prevent Regulatory

Penalties

Failure to maintain a compliant Master File can result in significant administrative fines and audit adjustments. Ensure your documentation is accurate, complete, and filed on time.

Frequently Asked Questions

What are the revenue thresholds for Master File applicability in the UAE?

Entities must maintain a Master File if they meet one of two conditions: the Taxable Person’s revenue in the relevant tax period is AED 200 million or more, or they are part of a Multinational Enterprise (MNE) Group with a consolidated group revenue exceeding AED 3.15 billion in the preceding financial year.

Is the Master File submitted automatically with the Corporate Tax Return?

Taxable Persons are not required to upload the Master File during the standard tax return filing. You must maintain the documentation internally and submit it to the Federal Tax Authority (FTA) strictly within 30 days of receiving a formal request.

How does the Master File differ from the Local File?

The Master File provides a high-level overview of the global MNE group, focusing on organizational structure, intangibles, and financial activities across all jurisdictions. The Local File focuses specifically on the local entity’s management structure and detailed transactional data to demonstrate that specific related-party transactions in the UAE adhere to the Arm’s Length Principle.

What are the consequences of failing to present a Master File?

Non-compliance attracts significant administrative penalties. Failure to submit the Master File within the 30-day window upon request results in statutory fines. Furthermore, the absence of documentation allows the FTA to make Transfer Pricing adjustments based on their own estimates, potentially increasing your tax liability.