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May 15, 2026

This Decision specifies the Transfer Pricing (TP) documentation requirements under Article 55 of the Corporate Tax Law. It mandates maintaining a Master File and Local File for two categories of Taxable Persons: members of a Multinational Enterprises Group with consolidated revenue of AED 3.15 billion or more, and Taxable Persons with revenue of AED 200 million or more. The Decision also details which related party transactions must be included in the Local File, such as those with non-residents or exempt persons, and which can be excluded, including transactions with certain resident persons.

This is not an Official Translation:

Requirements for Maintaining Transfer Pricing Documentation for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses

Ministerial Decision No. 97 of 2023

Issued 27 Apr 2023 – (Effective from the day following its publication in the Official Gazette)

[GTL Notes]

The Minister of State for Financial Affairs has decided:

Having reviewed the Constitution,
Federal Law No. 1 of 1972 on the Competencies of Ministries and Powers of the Ministers, and its amendments,
Federal Decree-Law No. 13 of 2016 on the Establishment of the Federal Tax Authority, and its amendments,
Federal Decree-Law No. 28 of 2022 on Tax Procedures,
Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,
Cabinet Decision No. 44 of 2020 on Organising Reports Submitted by Multinational Companies,

Article 1 - Definitions

Words and expressions in this Decision shall have the same meanings specified in the Federal Decree-Law No. 47 of 2022 referred to above (“Corporate Tax Law”) unless the context requires otherwise.

The Minister of State for Financial Affairs has decided:

Article 1 - Definitions

Article 2 - Conditions for Maintaining Master File and Local File