UAE Taxable Person
AED 200 million
UAE Taxable Person revenue reaches AED 200 million during the relevant Tax Period.
Transfer Pricing Master File and Local File Services in the UAE
Prepare your UAE transfer pricing documentation before an FTA request creates a 30-day deadline.
Bestax builds your Master File and Local File around your actual group structure. We review related party transactions, pricing methods, financial records, agreements, and benchmarking support. Your documentation stays aligned with your Corporate Tax return and business operations.
Threshold Testing FAR Analysis Benchmarking Support FTA Readiness
- FTA Approved
Tax AgencyNo. 30008692 - Business Setup Partner
for Dubai Free Zones - 10+YEARSof Experience
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Consultation
Tell us your UAE revenue, your group's consolidated revenue and where the parent sits. We will confirm which files the thresholds actually require, which related party transactions belong in the Local File, and what we need to start.
Transfer Pricing Documentation
Master & Local File Preparation for UAE Corporate Tax Compliance
Bestax provides Master & Local File Preparation for UAE businesses with related party and connected person transactions. We first confirm whether your business meets the current documentation thresholds.
Our team then maps the transactions requiring documentation and builds the supporting transfer pricing analysis. We reconcile the completed files with your accounting records and Corporate Tax information.
Bestax prepares the files around your actual commercial arrangements. We do not rely on generic transfer pricing templates.
Our service includes
- Master File and Local File threshold testing
- Group structure review
- Related party mapping
- Connected person review
- Controlled transaction mapping
- Functional, asset, and risk analysis
- Transfer pricing method selection
- Benchmarking coordination
- Intercompany agreement review
- Financial data reconciliation
- Master File drafting
- Local File drafting
- Corporate Tax disclosure reconciliation
- FTA request support
- Annual documentation updates
Confirm Your Master & Local File Preparation Thresholds
Bestax tests your revenue and group structure before starting full documentation. This prevents unnecessary work and identifies your exact UAE requirement.
A UAE Taxable Person enters the documentation threshold when either condition applies
MNE Group
AED 3.15 billion
MNE Group consolidated revenue reaches AED 3.15 billion during the relevant Tax Period.
Ministerial Decision No. 97 of 2023 (opens in a new tab) sets these thresholds for transfer pricing documentation.
UAE headquartered domestic group
A UAE headquartered domestic group receives different Master File treatment. A domestic-only group does not maintain a Master File.
The Local File still applies
The applicable entity still maintains a Local File when the required threshold is met. Bestax confirms this distinction before preparing documents.
Local File Scope
Map the Related Party Transactions That Belong in Your Local File
Not every related party transaction belongs inside the UAE Local File. Bestax identifies which transactions require inclusion under current rules.
We review your ownership structure, tax status, transaction counterparties, and applicable Corporate Tax rates. Our team then creates the Local File transaction inventory.
What sits outside it
Certain same-rate UAE related party transactions remain outside the Local File requirements. The arm's length principle still applies to those transactions.
Bestax separately documents excluded transactions when supporting evidence remains necessary. This keeps your Local File focused on the required transaction population.
The Local File generally includes transactions with
Non-Resident Persons
Exempt Persons
Resident Persons electing Small Business Relief
Resident Persons subject to a different Corporate Tax rate
Group level
Build Your UAE Master File Around the Actual Group Structure
Bestax prepares the Master File as a group-level transfer pricing document. We collect information from finance, tax, treasury, legal, and management teams.
The file explains how the wider multinational group creates value and allocates income. We connect this information with the group's transfer pricing policies.
Our Master File preparation covers
- Legal and ownership structure
- Geographic group structure
- Main business activities
- Important value drivers
- Principal supply chains
- Major geographic markets
- Group service arrangements
- Business restructurings
- Intangible assets
- Intellectual property ownership
- Research and development arrangements
- Intercompany financing
- Treasury activities
- Group transfer pricing policies
- Consolidated financial information
- Relevant tax positions
The FTA expects the Master File to provide a group-wide transfer pricing overview. Bestax structures the document around those requirements.
Entity level
Prepare a Local File That Matches Your UAE Entity
Bestax prepares the Local File around the UAE entity's actual functions and controlled transactions. We avoid copying group descriptions that do not match local operations.
Our team interviews management and reviews financial records, agreements, and operating processes. We then document what the UAE entity actually does.
Your Local File can include
- UAE management structure
- Organisation chart
- Business activities
- Business strategy
- Key competitors
- Related party transaction categories
- Transaction values
- Intercompany agreements
- Functional analysis
- Assets used
- Risks assumed
- Transfer pricing methods
- Tested party selection
- Comparable data
- Benchmarking results
- Financial information
- Arm's length conclusions
The FTA Local File guidance requires entity-specific business and controlled transaction information.
The Analysis That Sits Behind the Files
A Local File has to explain what each party contributes to the transaction, and the pricing method chosen for it needs economic support on the record.
Complete the Functional, Asset and Risk Analysis With Bestax
A strong Local File must explain what each party contributes to the transaction. Bestax performs the functional, asset, and risk analysis before selecting pricing methods.
We interview the people responsible for operations, finance, sales, procurement, and management. We compare actual conduct with written agreements.
Our FAR analysis covers
- Functions performed
- Decision-making responsibilities
- Assets used
- Intellectual property
- Employees involved
- Commercial risks
- Market risks
- Inventory risks
- Credit risks
- Foreign exchange risks
- Product liability risks
- Financing risks
- Control over significant risks
We use these findings to identify the economically relevant transaction. The analysis then supports the selected transfer pricing method.
Support Your Local File With Transfer Pricing Benchmarking
Bestax connects your Local File with appropriate economic support for the selected pricing method. We first determine which transaction requires external comparable data.
Our team defines the tested party, financial indicator, search criteria, and comparable company profile. We then document the economic reasoning supporting the arm's length result.
Benchmarking support can cover
- Management services
- Shared services
- Distribution activities
- Manufacturing arrangements
- Related party loans
- Intercompany financing
- Royalties
- Intellectual property licences
- Cost sharing arrangements
- Procurement services
- Sales support services
If your team needs a broader view of the documentation requirements, read our guide on transfer pricing documentation in the UAE.
Arrangement by Arrangement
Documentation Built Around the Arrangements You Actually Have
Intercompany agreements, Corporate Tax disclosures, a free zone position, related party financing and shared service charges each need their own evidence inside the files.
Review Intercompany Agreements Before Finalising Your Local File
Bestax compares written agreements with the transactions recorded in your accounts. Differences between contracts and actual conduct can weaken transfer pricing documentation.
We review the commercial terms and identify agreements requiring clarification. Our team also checks whether pricing clauses match the applied transfer pricing method.
Our agreement review covers
- Management service agreements
- Loan agreements
- Distribution agreements
- Licence agreements
- Royalty arrangements
- Cost allocation agreements
- Procurement agreements
- Shared service agreements
- Guarantees
- Cost contribution arrangements
- Intellectual property arrangements
We flag inconsistent terms before completing the Local File. Your documentation then reflects the transactions actually reported.
Reconcile Your Master File, Local File and Corporate Tax Return
Bestax checks that transfer pricing documentation matches your Corporate Tax return. We reconcile transaction values before the files reach final review.
The UAE Corporate Tax return contains separate schedules for qualifying related party transactions. Transactions exceeding the relevant disclosure thresholds require detailed reporting.
We reconcile
- Related party names
- Transaction categories
- Income values
- Expense values
- Transfer pricing methods
- Connected person payments
- Financial statement balances
- Local File figures
- Benchmarking results
- Corporate Tax return schedules
This reconciliation reduces unexplained differences between your tax return and supporting transfer pricing files.
Master & Local File Preparation for UAE Free Zone Companies
Bestax prepares transfer pricing documentation for free zone companies meeting the applicable thresholds. We also review the documentation against the company's free zone tax position.
Our free zone review covers
- Related party transactions
- Mainland transactions
- Foreign group transactions
- Management charges
- Financing arrangements
- Intellectual property
- Distribution arrangements
- Transfer pricing methods
- Local File requirements
- Master File requirements
- Corporate Tax disclosures
A Qualifying Free Zone Person must comply with the arm's length principle. Required transfer pricing documentation must also remain properly maintained.
Prepare Master & Local Files for Financing and Intercompany Loans
Bestax documents related party loans and financing arrangements within the transfer pricing framework. We review both pricing and commercial terms.
Our team examines whether the financing reflects an arm's length arrangement. We also document the functions and risks connected with treasury activities.
Our financing review includes
- Loan principal
- Interest rate
- Currency
- Loan term
- Repayment schedule
- Security
- Guarantees
- Borrower credit profile
- Lender functions
- Treasury structure
- Comparable financing terms
- Supporting agreements
The resulting analysis supports the financial transaction section within the required transfer pricing documentation.
Prepare Master & Local Files for Management and Shared Services
Bestax reviews charges for services provided between related companies. We document the service, recipient benefit, cost base, and applied pricing method.
Generic management fee descriptions create weak supporting evidence. Our team identifies what services were actually performed.
We review
- Service descriptions
- Employees providing services
- Recipient entities
- Cost pools
- Allocation keys
- Mark-ups
- Service agreements
- Supporting invoices
- Benefit evidence
- Duplicate services
- Shareholder activities
- Accounting entries
We then connect the analysis with the Local File and supporting benchmarking.
Ready for the Request, and Current in Every Tax Period
Documentation prepared contemporaneously is what a 30-day information request can actually be answered from, and a file only stays useful while it still describes the business it covers.
30 days
To reach the FTA once the files are requested
The Corporate Tax Law allows the FTA to request Master File and Local File documentation. Requested files must generally reach the FTA within 30 days.
Prepare Your Files Before the FTA Starts the 30-Day Clock
Bestax prepares transfer pricing documentation contemporaneously rather than waiting for an FTA information request. This gives your team time to resolve missing evidence.
We organise the final documents into an indexed response pack. Your finance team can then retrieve supporting records quickly.
Our FTA readiness review checks
- Current Master File
- Current Local File
- Benchmarking support
- Intercompany agreements
- Financial schedules
- Related party mapping
- Corporate Tax disclosures
- Accounting reconciliations
- Supporting calculations
- Management explanations
Review the official FTA Transfer Pricing Guide (opens in a new tab) for current documentation guidance.
Update Your Master File and Local File Each Tax Period
Bestax reviews transfer pricing documentation for each relevant Tax Period. We identify changes requiring updates before carrying forward earlier analysis.
A Master File must reflect the facts and circumstances of the relevant period. Local entity information must also stay consistent with current operations.
Our annual update review covers
- Revenue changes
- New group entities
- Ownership changes
- New related parties
- New transaction types
- Business restructurings
- New financing
- New intellectual property
- Pricing changes
- Functional changes
- Risk changes
- Updated financial results
- Benchmarking refresh requirements
This service prevents old transfer pricing documentation from becoming disconnected from current business operations.
How It Runs
Bestax Master & Local File Preparation Process
Bestax follows a structured documentation process. Each stage produces information needed for the next part of the file.
We Test Your Documentation Thresholds
We review UAE revenue, MNE group revenue, and group structure. We confirm which files your business needs.
We Map Related Parties and Transactions
Our team identifies counterparties, transaction types, values, and tax status. We determine which transactions enter the Local File.
We Collect Group and Entity Information
We request organisation charts, financial statements, agreements, policies, and business descriptions. Missing records are identified early.
We Perform the FAR Analysis
Bestax interviews relevant teams and documents functions, assets, and risks. We compare contracts with actual business conduct.
We Select Transfer Pricing Methods
We assess the available methods for each material transaction category. We document why the selected approach fits.
We Complete the Economic Analysis
Our team prepares or coordinates benchmarking where external support is required. We document the resulting arm's length range.
We Draft the Master File and Local File
We prepare the group-level and UAE entity documentation. Every section is supported by collected records.
We Reconcile the Files With Corporate Tax Reporting
We compare transaction values with financial statements and Corporate Tax schedules. Differences are corrected before finalisation.
We Deliver an FTA-Ready Documentation Pack
You receive final transfer pricing files and organised supporting schedules. Bestax also supports later FTA information requests.
Documents Bestax Requests for Master & Local File Preparation
Bestax provides a tailored information request after completing the initial scope review. The required documents depend on your transactions and group structure.
Common documents include
- Group organisation chart
- UAE entity organisation chart
- Consolidated financial statements
- UAE financial statements
- Trial balance
- Related party ledger
- Intercompany agreements
- Loan agreements
- Management service agreements
- Transfer pricing policies
- Group business descriptions
- Intellectual property records
- Financing information
- Corporate Tax return
- Related party disclosure schedules
- Previous benchmarking reports
- Previous Master Files
- Previous Local Files
We review the documents for consistency before drafting. Missing information receives a specific follow-up request.
Why Bestax
Why Choose Bestax for Master & Local File Preparation
Bestax combines Corporate Tax, accounting, transfer pricing, and FTA support within one UAE team. We build documentation using the financial records behind your Corporate Tax filing.
Our service focuses on creating files that management can explain and support. We also keep the documentation connected with actual related party transactions.
Review Ministerial Decision No. 97 of 2023 (opens in a new tab) for the official documentation thresholds.
Clients choose Bestax for
- FTA Approved Tax Agent support
- UAE transfer pricing experience
- Threshold assessment
- Related party mapping
- FAR analysis
- Transfer pricing method selection
- Benchmarking support
- Master File preparation
- Local File preparation
- Free zone reviews
- Corporate Tax reconciliation
- FTA information request support
- Annual file updates
Other Transfer Pricing and Corporate Tax Services
The same UAE team handles the work either side of your documentation.
Transfer Pricing Services
The whole UAE transfer pricing position: disclosure forms, documentation, benchmarking and audit defence.
Benchmarking Studies
The comparable search, the screening and the arm's length range that sits behind the Local File's method.
Policy & Structuring
Intra-group pricing policies set before the transactions happen, rather than defended after them.
Corporate Tax Services
Registration, computations, returns and advisory from an FTA-approved tax agency.
Corporate Tax Return Filing
The return your related party disclosures are reconciled against, prepared and filed by the same team.
Tax Agent in Dubai
A registered tax agent to hold the FTA correspondence when an information request arrives.
Frequently Asked Questions
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