Date of Publication: 06 May 2024
Master file is a Transfer Pricing (“TP”) documentation that provides a high-level overview of a Multinational Enterprise (“MNE”) Group’s global business operations, transfer pricing policies, information on key value drivers and a global allocation of income and economic activity.
Purpose
To assist the Tax Authorities (“FTA”) in:
(a) Evaluating significant TP risks
(b) Determining the MNE Group’s TP practices
Applicability
Or
Exception
Contents
Consequence of non-compliance
Levy of administrative penalties
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