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Master File Maintenance & Transfer Pricing Documentation in Dubai, UAE

Expert Master File preparation and maintenance for multinational groups. Al Aegis ensures your TP documentation meets OECD standards and UAE regulatory requirements.

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Government Agencies We Collaborate With

Federal Tax Authority (FTA)Ministry of Finance (MoF)Dubai Customs AuthorityAbu Dhabi CustomsEconomic Substance Regulations (ESR)Anti-Money Laundering (AML) AuthoritiesMinistry of EconomySecurities & Commodities Authority (SCA)

Overview

Master File Maintenance โ€” Comprehensive Transfer Pricing Documentation for Multinationals. Under the OECD's Base Erosion and Profit Shifting (BEPS) framework and UAE Corporate Tax Law, multinational enterprise (MNE) groups meeting certain revenue thresholds are required to maintain a Master File โ€” a high-level document providing an overview of the group's global business operations, organizational structure, intangible assets, intercompany financial activities, and transfer pricing policies. Al Aegis Corporate Services assists MNE groups in preparing and maintaining their Master File documentation to meet both UAE and international transfer pricing requirements. The Master File is a critical compliance document that must be available to tax authorities upon request and serves as the foundation for defending your group's transfer pricing positions across all jurisdictions. Our Master File services include a comprehensive review of your group structure, analysis of intercompany transactions and value chain, documentation of intangible assets and their ownership/use/development, description of intercompany financial arrangements, and articulation of your group's transfer pricing policies and their rationale. We ensure your Master File is prepared in accordance with OECD Action 13 standards and is consistent with your Local Files across all jurisdictions. Our team also provides annual maintenance and update services to keep your documentation current as your business evolves.

Key Features

Master File Preparation (OECD Action 13)
Group Organizational Structure Documentation
Intercompany Transaction Analysis
Intangible Asset Documentation
Financial Activity Overview
Transfer Pricing Policy Articulation
Annual Update & Maintenance
Consistency Review with Local Files

Why Choose Al Aegis?

OECD-Compliant Documentation

Our Master Files are prepared in strict accordance with OECD Action 13 standards, meeting the expectations of tax authorities worldwide.

Global Consistency

We ensure your Master File is consistent with Local Files prepared in other jurisdictions, avoiding contradictions that could trigger audit inquiries.

Comprehensive Coverage

Our documentation covers all required elements โ€” group structure, business activities, intangibles, financial arrangements, and TP policies.

Annual Maintenance

We provide ongoing maintenance services to keep your Master File current as your group structure, transactions, and policies evolve.

Audit Defense

A well-prepared Master File is your first line of defense in transfer pricing audits, demonstrating your group's commitment to arm's length compliance.

Multi-Country Coordination

We coordinate with your advisors in other jurisdictions to ensure a unified approach to TP documentation across the group.

Frequently Asked Questions

What is a Transfer Pricing Master File?
A Master File is a high-level TP document required for multinational groups. It provides an overview of the group's global operations, organizational structure, intangible assets, intercompany financial activities, and transfer pricing policies โ€” giving tax authorities a 'big picture' view of the group.
When is a Master File required in the UAE?
Under UAE CT law, MNE groups with consolidated revenues exceeding AED 3.15 billion are required to maintain a Master File. It must be available to the FTA upon request.
How does the Master File differ from the Local File?
The Master File provides a group-level overview, while the Local File focuses on specific intercompany transactions of a particular entity within the group. Together, they form the complete TP documentation package.
How often should the Master File be updated?
The Master File should be updated annually to reflect changes in group structure, business operations, intercompany transactions, and TP policies. Al Aegis provides annual maintenance services to keep your documentation current.
What happens if we don't maintain a Master File?
Failure to maintain required TP documentation can result in penalties from the FTA and may weaken your defense in transfer pricing audits. Tax authorities may make unfavorable TP adjustments if documentation is insufficient.

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