The core transfer pricing documentation under UAE Corporate Tax Law.
The Local File and Master File are the two core transfer pricing documentation reports required under UAE Corporate Tax Law for businesses that meet the applicable thresholds, in line with OECD BEPS Action 13 standards.
% At A Glance
Master File covers group-wide transfer pricing policy and structure
Local File covers your entity's own related-party transactions in detail
Both support your Corporate Tax return and any FTA request
Who Needs This
If you meet the threshold, both files are mandatory.
Applies to UAE taxable persons that meet the Corporate Tax Law's thresholds for related-party transaction value, or that are part of a Multinational Enterprise Group, as defined under the relevant Ministerial Decision.
Timing
When you need this ready by.
Both files must be maintained and ready to submit to the FTA within the timeframe specified in a request. They should be prepared alongside your Corporate Tax return, not scrambled together after a request arrives.
What You'll Need
Documents for your Local File and Master File.
Group organizational chart
List of related-party transactions
Existing transfer pricing policies
Financial statements (entity and group level, where available)
Prior year's Local File and Master File, if any
Why This Matters
What's at risk without both files ready.
Failure to provide the Local File or Master File within the FTA's requested timeframe can result in an administrative penalty
Incomplete documentation increases audit risk
Proactive preparation avoids scrambling under a tight FTA deadline
Why This Matters
How your related-party transactions affect your Corporate Tax rate.
The Local File and Master File don't have their own rate — but the related-party pricing they document directly affects how much of your income falls into the taxed band below.
Taxable income up to AED 375,0000%
Taxable income above AED 375,0009%
Why Choose HayyaTax
OECD-aligned documentation, ready before it's requested.
Local File and Master File preparation handled by the same team managing your wider Corporate Tax compliance.
FTA-Approved Tax Agent
Backed by a firm authorized to represent you directly with the Federal Tax Authority.
OECD-Aligned Documentation
Both files prepared to the BEPS Action 13 standard the UAE has adopted.
Corporate Tax & Transfer Pricing Under One Roof
Handled by the same team managing your Corporate Tax and Transfer Pricing compliance.
Practical Turnaround
Documentation prepared ahead of time, not scrambled under a tight FTA deadline.
How It Works
From scoping to filing-ready documentation.
1
Step 01
Scoping & Threshold Review
We confirm whether your group meets the Local File and Master File thresholds.
2
Step 02
Master File & Local File Drafting
We prepare both files covering your group's TP policy and your entity's own related-party transactions.
3
Step 03
Review & Filing-Ready Delivery
You receive both files reviewed and ready to submit if the FTA requests them.
4
Step 04
Annual Refresh
We update both files each year as your related-party transactions and group structure evolve.
What Non-Compliance Costs You
What's at risk, and how we help.
ViolationPenaltyHow HayyaTax helps
Missing Local File or Master File when requested by the FTAAdministrative penalty may applyWe prepare both in advance so they're ready before any request arrives
Incomplete or outdated documentationIncreased audit riskWe keep documentation current each filing cycle
Why work with HayyaTax
Excellence. Expertise. Experience.
📅
10+
Years of Experience
Hands-on UAE tax and accounting work across the team.
📋
FTA
Approved Tax Agent
Authorized to represent clients directly with the Federal Tax Authority.
👨💼
Expert
Professional Team
Qualified tax and accounting professionals supporting every engagement.
📊
OECD-Aligned
Methodology
Comparable-based reviews aligned with arm's-length principles.
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FTA Credentials
An FTA-registered & approved tax agency in the UAE.
HayyaTax is an FTA-approved Tax Agent, authorized to represent clients directly with the Federal Tax Authority — the same team preparing your Local File and Master File also manages your wider Corporate Tax compliance.
✅ FTA-Approved Tax Agent
✅ Direct FTA Representation
✅ Corporate Tax & TP Under One Roof
FTA-Approved Tax Agent
Authorized to represent clients directly with the Federal Tax Authority.
TAN30016448
Common questions
Frequently asked questions on the Local File and Master File.
What's the difference between the Local File and the Master File? ⌄
The Master File covers your group's overall transfer pricing policy and structure. The Local File focuses on your specific entity's own related-party transactions in detail.
Who must prepare them? ⌄
UAE taxable persons that meet the Corporate Tax Law's thresholds for related-party transaction value, or that belong to a Multinational Enterprise Group, as defined under the relevant Ministerial Decision.
How long do we have to submit them if the FTA requests them? ⌄
The FTA specifies a timeframe in its request — this is why we recommend having both files ready in advance rather than starting once a request arrives.
How does this relate to Transfer Pricing Benchmarking? ⌄
Benchmarking supports the pricing analysis referenced inside these files. See our TP Benchmarking page for that specific service.
Does every business need a Local File and Master File? ⌄
No — only those meeting the applicable thresholds. We'll confirm whether your group qualifies as part of the initial review.
Testimonials
What clients say about HayyaTax.
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