Maldives master file and local file requirements (2026)

Does the Maldives require a master file and a local file?

Yes, for any company liable to Maldivian income tax that trades with an associate, unless one of two exemptions applies. The Maldives Inland Revenue Authority runs the three-tiered approach: a master file, a local file and a country-by-country report. The authority sets the regime out on its transfer pricing page^[1], and the detail sits in the 2020 transfer pricing regulation^[2].

Who counts as an associate in the Maldives?

Two parties are associates when one controls the other, or both sit under common control. Relatives count, so do partners in the same partnership and the settlor and beneficiary of the same trust. A head office and its Maldivian permanent establishment are treated as associates of each other. There is no percentage test. The Maldives uses control rather than a shareholding line, as the 2019 income tax law^[3] sets out.

For an inbound group the usual case is a resort operating or management company in the Maldives paying management fees, royalties, intercompany loan interest or procurement charges to companies in its own group.

Which companies are exempt from Maldives transfer pricing documentation?

Two exemptions, and they measure different things. One looks at the size of your related-party dealings, the other at the size of your business. Either one removes the master file and the local file together.

What goes in the Maldives master file and local file?

The master file carries the group: structure, business, intangibles, intercompany financing and the consolidated financial position. The local file carries the Maldivian entity: its related-party transactions, the functional analysis behind them, the method chosen and the benchmarking. Both follow the OECD content annexes, which the OECD country profile for the Maldives^[4] records.

Does country-by-country reporting apply in the Maldives?

Yes, for fiscal years from 1 January 2021. A group whose ultimate parent had more than EUR 750 million of consolidated revenue in the preceding fiscal year is in scope. The report is due within 12 months of the fiscal year end. Every Maldives-resident company in that group notifies the tax authority by email by the last day of the reporting fiscal year, whether or not it files the report itself. The authority publishes the notification route^[5].

Is there a Maldives transfer pricing form?

One, and it sits inside the corporate income tax return. Schedule 4 of Form MIRA 604, "Reporting Dealings with Associates", is the related-party disclosure. There is no separate standalone transfer pricing form. The master file and the local file are not attached to the return at all.

When is Maldives transfer pricing documentation due?

The files must be finished by the tax return due date for the accounting period, then produced on request. The country-by-country dates are fixed and do not move with your return.

What language and currency does the tax authority accept?

English or Dhivehi. For a foreign parent that is worth money: an English-language group master file is usable in the Maldives as it stands, with no translation. The currency the documentation has to be presented in is not confirmed from a primary source, so this page does not state one.

What are the penalties for missing Maldives transfer pricing documentation?

There is no transfer pricing penalty of its own. A missing file is sanctioned under the general tax administration rules, and the amounts are not published in a form we can confirm, so no figure is given here. The real exposure is the adjustment. The tax authority can recompute your taxable income on arm's length terms whatever your contracts say, and without documentation the burden of showing otherwise is yours.

Are there safe harbours in the Maldives?

Two, both confirmed. Routine support services supplied only inside the group may be charged at cost plus 5%. Intercompany loans up to MVR 15 million are exempt from documentation where both parties apply the indicative margin the tax authority publishes, and that margin is reset at the start of each year.

Can you get an advance pricing arrangement in the Maldives?

Yes, since 16 March 2021, and unilateral, bilateral and multilateral arrangements are all available. A term cannot run longer than five consecutive years. Rollback to earlier years is decided case by case, a non-refundable application fee may apply, and a bilateral or multilateral arrangement needs a treaty or exchange agreement behind it to support the mutual agreement procedure. The authority publishes the application route^[6].

How do Maldives rules differ from the OECD baseline?

The Maldives is not an OECD member. It is a member of the Inclusive Framework on base erosion and profit shifting^[7], so the OECD guidelines are the interpretive reference and country-by-country reporting follows the OECD minimum standard. The tax authority's transfer pricing guide was last updated on 4 December 2025.

Three differences matter in practice. Local comparables are preferred, and regional data is accepted only where reliable local data is missing. The rules are young, so published audit practice is thin and a contemporaneous file carries more weight rather than less. Several operational points, including the documentation currency and the exact penalty amounts, are genuinely not confirmed.

How we help with Maldives transfer pricing

The Maldivian entity carries the duty, but the master file and the group data come from the parent, and the file has to be ready before the tax authority asks rather than after. We build the benchmarking and the functional analysis, draft the master file and the local file, and keep the country-by-country notification on the calendar. See how our transfer pricing software works.

Book a demo to get a documentation gap assessment for your Maldivian entity before your next return.