Maldives Transfer Pricing Documentation Requirements
The Maldives requires a Master File and Local File from taxpayers with related-party transactions, exempting micro, small, and medium enterprises under the SME law. A reporting schedule applies where annual income exceeds MVR 20 million, and documentation is produced within 30 days of a request.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Taxpayers with related-party transactions (MSMEs under the SME law exempt) | By tax return due date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | EN | Under the Tax Administration Act |
Local File Required | Same MSME exemption as the Master File | By tax return due date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | EN / local | Under the Tax Administration Act |
Schedule 04 International transactions report
Annual filing | Taxpayers with annual income above MVR 20m | By 30 June following the tax year | Submission deadline The documentation must be filed with the tax authority by the date shown. | EN | Yes |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Maldives deadline
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Scope of the documentation obligation
A Maldives entity with related-party transactions must hold a Master File and Local File, with an exemption for entities classified as micro, small, and medium enterprises under the SME law, which sets thresholds by employee count and turnover. A reporting schedule, Schedule 04, covering international transactions with associates, must be completed where the taxpayer’s total annual income exceeds MVR 20 million, approximately USD 1.2 million, as part of the income tax return. Documentation is produced within 30 days of a request.
Distinctive features of the Maldivian regime
Two features distinguish the Maldivian regime. The first is the SME exemption, which carves out micro, small, and medium enterprises defined under the separate SME law by employee numbers and turnover, focusing the documentation duty on larger entities. The second is the penalty mechanism: the transfer pricing regulation itself does not set penalties, so a taxpayer that fails to submit required documentation falls under the penalties of the Tax Administration Act, and a taxpayer that cannot show its prices are at arm’s length, whether through its documentation or its absence, faces adjustment on that basis. Benchmarking is required principally to determine arm’s length interest rates.
Benchmarking and comparables
A benchmarking analysis is required to determine the arm’s length interest rate; otherwise benchmarking is not specifically prescribed in the transfer pricing guides or regulations. The choice between single-year and multi-year testing is not specified, nor is the frequency of a fresh search. A tax audit notice may be initiated at any time, and the tax authority may generally serve a notice within two years of the return filing deadline or actual filing date, with no time limit where a return is not filed or fraud is involved.
Frequently asked questions
Are small businesses exempt from documentation in the Maldives?
Yes. Entities classified as micro, small, and medium enterprises under the SME law, defined by employee count and turnover, are exempt from the Master File and Local File requirement.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.