Annex I to Chapter V of these Guidelines sets out the information to be included in the master file.
TPG2017 Chapter V paragraph 5.21
Posted on |
By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Master file, Transfer pricing documentation
« Prev |
Next » Related Guidelines
- OECD COVID-19 TPG paragraph 95When considering the consequences of the failure to meet critical assumptions, tax administrations and taxpayers should consider the (i) terms of the APA; (ii) any agreement between relevant tax administrations as to how to deal with the failure; and (iii) any applicable domestic law or procedural provisions.45 This section follows...
- TPG2022 Chapter V paragraph 5.19The information required in the master file provides a “blueprint” of the MNE group and contains relevant information that can be broken down into five categories: a) the MNE group’s organisational structure; b) a description of the MNE group’s business or businesses; c) the MNE group’s intangibles; d) the MNE...
- TPG2022 Chapter V paragraph 5.23Annex II to Chapter V of these Guidelines sets out the items of information to be included in the local file....
- TPG2022 Chapter V paragraph 5.50It is recommended that the first Country-by-Country Reports be required to be filed for MNE fiscal years beginning on or after 1 January 2016. However, it is acknowledged that some jurisdictions may need time to follow their particular domestic legislative process in order to make necessary adjustments to the law....
- TPG2022 Chapter II paragraph 2.174Where comparable uncontrolled transactions of sufficient reliability are lacking to support the division of the relevant profits, consideration should be given to internal data, which may provide a reliable means of establishing or testing the arm’s length nature of the division of profits. The types of such internal data that...
- TPG2022 Chapter VIII paragraph 8.52The following information would be relevant and useful concerning the initial terms of the CCA: a) a list of participants b) a list of any other associated enterprises that will be involved with the CCA activity or that are expected to exploit or use the results of the subject activity...
- TPG2022 Chapter IX paragraph 9.33As part of their transfer pricing documentation, MNE groups are recommended to document their decisions and intentions regarding business restructurings, especially as regards their decisions to assume or transfer significant risks, before the relevant transactions occur, and to document the evaluation of the consequences on profit potential of significant risk...
- TPG2022 Chapter V paragraph 5.21Annex I to Chapter V of these Guidelines sets out the information to be included in the master file....
- TPG2022 Chapter V paragraph 5.22In contrast to the master file, which provides a high-level overview as described in paragraph 5.18, the local file provides more detailed information relating to specific intercompany transactions. The information required in the local file supplements the master file and helps to meet the objective of assuring that the taxpayer...
- OECD COVID-19 TPG paragraph 92Most APAs include critical assumptions about the operational and economic conditions that will affect the transactions covered by the APA. The COVID-19 pandemic and the response of governments have dramatically affected the economic and market conditions and are likely to qualify as a breach of the critical assumptions (para. 44...