01
Document overview
Sets the thresholds and content framework for UAE corporate-tax master files and local files, including included and excluded transactions.
- Group threshold: AED 3.15 billion.
- Taxable-person threshold: AED 200 million.
- FTA guidance does not replace the instrument.
02
Scope and exclusions
Applies to
A master/local file is required, among other cases, where consolidated group revenue is at least AED 3.15 billion or the taxable person's revenue is at least AED 200 million.
Limitations and exclusions
Not every related-party transaction belongs in the local file; specific rules apply to residents, non-residents, exempt persons and natural persons.
03
Document text
This is an independent editorial overview, not the official text or a complete translation. Application requires checking the Arabic original, current version and transitional provisions.
An independent four-language editorial overview is published; the full instrument is not yet reproduced on-site.. This is an independent editorial overview, not the official text or a complete translation. Application requires checking the Arabic original, current version and transitional provisions.
04
Publication status
Source and translation status
The official Arabic text controls; the English version on the official portal is for reference. This page contains an independent SGC editorial overview.
Legal review
Number, date, scope, principal exclusions, effective status and official URL were checked; the overview is not advice on a specific matter. · September 13, 2026
Republication status
Only instrument metadata, an official deep link and an original editorial explanation are used. The FTA/MoF PDF, layout and compilation are not copied; full-text reproduction requires a separate source and rights review.
Change history
- 27 April 2023 — issued; effective the day after official publication.
- Reviewed 13 September 2026
06
Official primary source
Ministerial Decision No. 97 of 2023
Only instrument metadata, an official deep link and an original editorial explanation are used. The FTA/MoF PDF, layout and compilation are not copied; full-text reproduction requires a separate source and rights review.
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