Transfer Pricing Documentation Translation for the UAE FTA
The Short Answer
UAE corporate tax applies the arm’s length principle to transactions between related parties and connected persons (Articles 34 and 35 of Federal Decree-Law No. 47 of 2022 on Corporate Tax). Under Article 55, businesses disclose those transactions with their tax return, and larger businesses must also keep a master file and a local file and produce them within 30 days of a request from the Federal Tax Authority (FTA), or by a later date the FTA allows.
These files are usually prepared in English, often by a foreign parent company. Article 5 of the Tax Procedures Decree-Law (No. 28 of 2022) makes Arabic the language of dealings with the FTA. The FTA may accept English, but it can ask for an Arabic translation at the taxpayer’s cost, and intercompany agreements written in German, French, Chinese or another third language almost always need one. A 30-day window leaves little time to find a translator once the request arrives.
Smart World Legal Translation (SWLT) is an MOJ-licensed legal translation office in Abu Dhabi that translates transfer pricing files and the contracts behind them. We translate; we do not prepare benchmarking studies or give tax advice. For the wider picture of FTA translation, see our guide to tax document translation for the FTA.
Who Has to Keep a Master File and Local File
Ministerial Decision No. 97 of 2023 sets the thresholds. A taxable person must maintain both files if, in the relevant tax period, either test is met:
- Its own revenue is AED 200 million or more, or
- It belongs to a multinational group with consolidated revenue of AED 3.15 billion or more.
Businesses below both thresholds do not need the two files, but they still file the related party disclosure with the return when they have qualifying transactions, and the FTA can still ask for the contracts and invoices behind those figures during a review. Confirm your own position with your tax adviser; the official text is on the Ministry of Finance and FTA websites.
Which Transfer Pricing Documents Usually Get Translated
| Document | Typical language | When translation comes up |
|---|---|---|
| Master file | English, prepared by the group | The FTA asks for Arabic, or the file is challenged in a dispute |
| Local file | English, prepared locally or by advisers | The FTA asks for Arabic during a review or audit |
| Intercompany agreements | Often the parent’s language: German, French, Chinese, Japanese | Almost always, when the agreement is not in Arabic or English |
| Board resolutions and approvals | Parent or subsidiary language | When they evidence the terms or approval of a related-party transaction |
| Invoices and cost allocation schedules | Mixed | When the FTA tests the figures behind management fees or recharges |
| Audited financial statements | English | On request, and for objections or disputes |
What a Good Translation of a TP File Gets Right
A transfer pricing file is read alongside your tax return and financial statements. The translation must not create inconsistencies the original did not have:
- Figures match to the dirham. Amounts, currencies, exchange rates and percentages are reproduced exactly, with the same rounding as the original.
- Entity names match the trade licence. Group companies are named exactly as on their licences and registrations, in Arabic and in Latin script, every time.
- Methods are named consistently. Terms such as comparable uncontrolled price, transactional net margin method, interquartile range or cost plus mark-up are rendered the same way throughout, and match the terms used in the return.
- Functional analysis keeps its meaning. Descriptions of functions, assets and risks are translated for meaning, because a loose word can shift which entity appears to control a risk.
- Tables and appendices are complete. Benchmarking tables, organisation charts and agreement schedules are translated, not dropped.
We build a short glossary for each group at the start and reuse it for the agreements, the local file and later years. Our guide to legal terms machine translation gets wrong shows why we do not rely on raw machine output for documents like these.
How to Prepare Before the FTA Asks
1. List your related-party transactions
Management fees, loans, guarantees, cost sharing, royalties and sales of goods or services. Your tax adviser decides which ones the files cover.
2. Collect the signed agreements
Find the signed intercompany agreements and any amendments. Agreements in a third language are the ones that take longest to translate, so start with those.
3. Translate the core contracts first
Translating the agreements while the local file is being written lets the file quote the Arabic terms consistently. See our commercial contract translation service.
4. Keep the files ready to translate
If the master and local files exist only in English, keep editable versions. When a 30-day request arrives, we can start at once instead of working from scanned PDFs.
Frequently Asked Questions
Must the master file and local file be in Arabic?
Not automatically. Arabic is the official language of dealings with the FTA, which may accept English but can ask for an Arabic translation. Check the request you receive and ask your tax adviser.
Do you prepare the transfer pricing study?
No. Benchmarking, functional analysis and pricing conclusions are prepared by your tax adviser. We translate what they and your group prepare.
How long does a full TP file take to translate?
It depends on length and source language. A local file with its key agreements is usually a matter of days, not weeks; we confirm the timeline when we quote, so it fits inside the FTA’s deadline.
Can you work with our group glossary?
Yes. Send any existing glossary or past Arabic filings and we will align the terminology with them.
How is it priced?
Per page of the source document. From AED 80 per 200-word page for Arabic and English, AED 100 for French, AED 150 for German, Italian or Turkish, and AED 250 for other languages such as Chinese, Russian or Urdu (all excl. 5% VAT). Urgent work is priced on request, and large files receive discounts.
Disclaimer
This article is general information about the language side of transfer pricing compliance. It is not tax advice. Thresholds, deadlines and FTA practice can change, so confirm your obligations with a registered tax agent or adviser and the current FTA guidance.
Translate Your Transfer Pricing File Before the Clock Starts
Send us the local file, master file or intercompany agreements and we will quote a timeline that fits the FTA’s 30-day window. For audited accounts, see our financial statements translation service. Smart World Legal Translation is led by Dr. Hani Elimam (MOJ-licensed translator, AIIC member), has translated legal documents since 2014 and is rated 4.8/5 on Google. Send your documents on WhatsApp (+971 54 360 8305), email info@swlt.ae, or use our contact page.