Transfer Pricing

The UAE master-file: a working checklist

What belongs in the master file, what can wait for the local file, and how boards should ask for evidence.

TK

Tahir Ali Khan

Director · Tax Advisory · July 2026 · 6 min read

A master file is not a brochure. It is the group narrative examiners use to test whether local pricing stories hold. This checklist is for finance and tax leads who need a working artefact, not a filing shelf.

Build once, refresh deliberately

Organisational structure, intangibles, financing, and value-chain descriptions should be owned — with a refresh cadence tied to reorganisations, not calendar folklore.

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