The UAE Ministry of Finance has published Ministerial Decision No. 97 of 2023, which sets out the transfer pricing documentation requirements for the purpose of Federal Decree-Law No. 47 of 2022 (the Corporate Tax Law). This includes that a taxable person that meets either of the following conditions must maintain both a master file and a local file in the relevant tax period: At any time during the relevant tax period, the taxable person is a constituent company of a multinational enterprises group as defined in the Cabinet Decision No. 44 of 2020 (CbC reporting) that has a total consolidated...