ZeroSync Accountants prepares audit-ready Master File and Local File documentation for larger UAE taxpayers and multinational groups, aligning the group story, UAE controlled transactions, benchmarking and tax return disclosures.
Best for larger UAE taxpayers, UAE subsidiaries of multinational groups, regional headquarters, free zone hubs and entities with significant related-party transactions.
For larger UAE taxpayers, transfer pricing documentation usually takes a two-part form. The Master File explains the multinational group, while the Local File analyses the UAE entity’s controlled transactions.
Both files must be consistent with each other, the disclosure form, the corporate tax return, the intercompany agreements and the financial statements.
| Trigger | Threshold | Result |
|---|---|---|
| UAE revenue | At least AED 200 million in the tax period | Master File and Local File required |
| MNE group revenue | At least AED 3.15 billion consolidated group revenue | Master File and Local File required |
| Below thresholds | Not normally required | Disclosure form may still apply |
| Section | What it covers |
|---|---|
| Group structure | Legal, ownership and operational structure of the group |
| Business overview | Main profit drivers, value chain and supply chain |
| Intangibles | Ownership, development and exploitation of intellectual property |
| Intercompany financing | How the group is financed and how finance transactions are priced |
| Financial and tax position | Group financial statements, rulings, APAs and overall tax position where relevant |
| Section | What it covers |
|---|---|
| Local entity profile | Management, business strategy and UAE entity role |
| Controlled transactions | Nature and value of related-party transactions |
| Functional analysis | Functions performed, assets used and risks assumed |
| Method selection | Chosen transfer pricing method and why it is the best fit |
| Benchmarking | Comparable analysis proving the result is arm’s length |
| Financial reconciliation | Connection to accounts, tax return and disclosure form |
The Master File is the map. The Local File is the street view. They must tell the same story.
We confirm whether the files apply and define the documentation scope by entity and transaction.
We document the functions, assets and risks of each party to the controlled transactions.
We run comparable analyses that support the selected pricing method and margin.
We prepare Master and Local Files to a UAE and OECD-aligned content standard.
We check that files align with disclosure forms, accounts and intercompany agreements.
We refresh the files each period so they remain contemporaneous and useful.
Benchmarking identifies independent companies or transactions that are comparable to your controlled transaction. The analysis then tests whether the related-party pricing or margin falls within an arm’s length range.
Poor benchmarking can be picked apart quickly. It needs the right tested party, search strategy, screening logic, accepted and rejected comparables, current data and a conclusion that reconciles with the financials.
| Benchmarking issue | Why it matters |
|---|---|
| Wrong tested party | The analysis may not match the transaction risk profile |
| Old data | The result may no longer reflect the period being filed |
| No rejection rationale | The comparable set looks arbitrary |
| No reconciliation | The analysis does not tie back to the accounts |
Many UAE subsidiaries receive a group Master File from headquarters. That can be useful, but it still needs to be checked for UAE consistency, especially where local transactions, management structures, intangibles or financing arrangements differ from the group summary.
ZeroSync can review the overseas Master File, identify gaps and prepare a UAE Local File that aligns with both group finance and local filing requirements.
The best files are not written in isolation. We coordinate with group finance, UAE accounting teams and tax return preparers so figures and narratives match across the full compliance pack.
ZeroSync supports regional headquarters, holding companies, trading hubs, distributors, service entities and UAE subsidiaries of multinational groups operating across Dubai and the wider UAE. The files are written for audit readiness, not only for checklist completion.
| Entity type | File focus |
|---|---|
| Regional headquarters | Group value chain, management services and support fees |
| Distribution hubs | Margins, resale pricing and goods flow analysis |
| Holding companies | Dividends, intangibles, financing and shareholder activity |
| Service centres | Cost-plus support and benefit evidence |
| Free zone entities | Consistency with QFZP and arm’s length requirements |
These links connect this page to live ZeroSync service pages and tools that visitors can use now.
Corporate Tax Services DubaiCorporate Tax AdvisoryCorporate Tax Return FilingQFZP Assessment and FilingUAE Corporate Tax CalculatorCorporate Tax Deadline CheckerBookkeeping Services DubaiFinancial Statement ServicesContact ZeroSyncA strong file connects group facts, local transactions, benchmarking and financial statements. ZeroSync prepares files that are consistent, current and ready for FTA review.
The Master File explains the whole group, including structure, business, intangibles, financing and overall tax position. The Local File focuses on the UAE entity’s controlled transactions, functional analysis, method selection and benchmarking.
The files are generally required when the taxable person has revenue of at least AED 200 million in the tax period or is part of an MNE group with consolidated group revenue of at least AED 3.15 billion.
UAE transfer pricing documentation requirements are aligned with the OECD approach, with UAE-specific requirements under the relevant corporate tax decisions and guidance.
The files must be maintained and produced when requested by the FTA within the period stated in the request. Preparing them contemporaneously avoids a rushed response.
That is common. ZeroSync reviews the overseas Master File for UAE consistency and prepares the UAE Local File so the documents reconcile with each other.
Inconsistent or superficial files can undermine the position by exposing gaps between the stated structure, the accounts and the pricing. Strong files need consistent facts, figures and methods.
A defensible benchmarking study uses appropriate comparables, a clear method, documented screening and rejection logic, current data and a result that reconciles with the tested transaction.
Yes. ZeroSync can review a group-prepared Master File, identify UAE gaps and prepare a Local File that aligns with group finance and UAE corporate tax filing.
