TP Master File and Its Contents

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

• Taxable person that is part of a MNE Group with consolidated group revenue > AED 3.15 billion.

Or

• Taxable person’s revenue during the relevant tax period is > AED 200 million.

Exception

• Taxable Person part of a UAE headquartered group.

Contents

• MNE Group’s organizational structure
• Description of the MNE Group’s business(es)
• MNE Group’s financial and tax positions
• MNE Group’s intercompany financial activities
• MNE Group’s intangibles (as defined in Chapter VI of the OECD TP Guidelines)

Consequence of non-compliance

Levy of administrative penalties

How Can Crowe Help?

• Examining the applicability of Master file documentation requirements.
• Assisting in the preparation of Master file in accordance with the UAE TP provisions.
• Assisting in updating the Master file for each tax period.