This Decision specifies the Transfer Pricing (TP) documentation requirements under Article 55 of the Corporate Tax Law. It mandates maintaining a Master File and Local File for two categories of Taxable Persons: members of a Multinational Enterprises Group with consolidated revenue of AED 3.15 billion or more, and Taxable Persons with revenue of AED 200 million or more. The Decision also details which related party transactions must be included in the Local File, such as those with non-residents or exempt persons, and which can be excluded, including transactions with certain resident persons.