In the master file (see Annex I to Chapter V), taxpayers are asked to describe any important business restructuring transactions occurring during the year. In addition, in the local file, taxpayers are asked to indicate whether the local entity has been involved in or affected by business restructurings occurring during the year or immediately past year and to explain the aspects of such transactions affecting the local entity (see Annex II to Chapter V).
TPG2017 Chapter IX paragraph 9.32
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Business restructuring, Delineation of Business Restructurings
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