Master File
BEPS Action 13 has also incorporated a new Report, mandatory in the jurisdictions being under this regulation
called Master File, which collects standardized information at the corporate group level, including the nature of
their global transactions, their Transfer Pricing policies, and the distribution of their profits, and economic
activities worldwide.
In order to enable tax administrations to assess whether there is a significant Transfer Pricing risk.
Following the OECD (Organization for Economic Co-operation and Development) Transfer Pricing Guidelines, the
Master File’s purpose is to provide a high-level overview to place the multinational group Transfer Pricing practices in
their global economic, legal, financial, and tax context.
We provide support for compliance with the information the Master File must contain, which are relevant data that
can be grouped into five categories:
Master File Content
- Organizational structure of the corporate group
- Intangible assets of the corporate group
- Financial and tax positions of the corporate group entities
- Intragroup financial activities
- Description of the corporate group's businesses
