Master File
Action 13 of the BEPS has also incorporated a new Report, mandatory in the jurisdictions that are under this regulation called Master Report that collects standardized information at the level of the business group, including the nature of its global operations, its transfer pricing policies and the distribution of its global benefits and economic activities, to enable tax administrations to assess whether there is a significant transfer pricing risk.
According to the guidelines of the OECD (Organisation for Economic Cooperation and Development) Transfer Pricing Guidelines, the master file is intended to provide a high-level overview with a view to place the transfer pricing practices of the multinational group in its global economic, legal, financial and fiscal context.
We provide support for the fulfillment of the information that should be contained in the Master File, which contains relevant data that can be grouped into five categories:
Master File Information
- The organisational structure of the enterprise group
- Intangible assets of the business group
- Financial and tax positions of corporate group entities
- Intra-group financial activities
- Description of deals of the business group
