Tax
Transfer Pricing Master & Local File
The master file describes your group; the local file defends your UAE entity's transactions inside it. We prepare both so they say the same thing, and so the local file reflects what your entity actually does.
Why it matters
Why Transfer Pricing Master & Local File matters
These are two documents with two audiences, and the most common failure is that they contradict each other.
The two files have to agree
A local file describing functions the master file does not recognise is a problem you have created yourself.
Functional analysis is the core
What your entity does, what it owns and what risks it carries is what determines the pricing.
It has to be current
Documentation prepared once and rolled forward unchanged stops describing the business it covers.
What we provide
What the engagement covers
Master file preparation
Group structure, business description, intangibles, intra-group financing and the group's financial position.
Local file preparation
The UAE entity's controlled transactions, functional analysis, method selection and supporting financials.
Functional analysis
Interviews with the people who run the business, so the analysis describes reality rather than an org chart.
Consistency review
The two files read against each other, and against your return disclosures, before either is finalised.
Annual refresh
Updating the files as the group changes, rather than reproducing last year's.
How it works
The process, step by step
Scope
Transactions and entities in scope identified and agreed.
Interview
The people who actually run the functions are talked to.
Draft
Both files drafted, with the method selection reasoned.
Reconcile
Files checked against each other and against your disclosures, then issued.
Outcomes
What you get
Two documents that agree with each other and with your return
A functional analysis built from interviews, not assumptions
Method selection with the reasoning on the record
A file that can be refreshed rather than rebuilt each year
Who it is for
Built for businesses like yours
UAE entities in groups meeting documentation requirements
Businesses preparing a master and local file for the first time
Groups whose existing documentation has not kept pace
Companies whose functional profile has changed
Questions
Transfer Pricing Master & Local File: common questions
Often it is a good starting point but not sufficient on its own, because the local file has to address your UAE entity specifically. We work from the group file rather than duplicating it.
A few interviews with the people who run the relevant functions. That is the part that cannot be outsourced, and it is what makes the analysis credible.
Talk to a senior about transfer pricing master & local file
Free consultation, no obligation, and a reply in under 30 minutes during working hours.