Ministerial Decision No. 97 of 2023 Requirements for Maintaining Transfer Pricing Documentation for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses

Minister of State for Financial Affairs:

- 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,

Decided: 

Article 1 — Definitions 

The terms 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.  

Article 2 — Conditions for Maintaining Master File and Local File 

1. A Taxable Person that meets either of the following conditions shall maintain both a master file and a local file in accordance with Clause (2) of Article 55 of ...