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.
05
Official primary source
Ministerial Decision No. 97 of 2023
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