TPG2022 Chapter V paragraph 5.16

Posted on | By OECD
Category: OECD Transfer Pricing Guidelines (2022), TPG2022 Chapter V: Transfer Pricing Documentation | Tag: ,
« | »

In order to achieve the objectives described in Section B, jurisdictions should adopt a standardised approach to transfer pricing documentation. This section describes a three-tiered structure consisting of (i) a master file containing standardised information relevant for all MNE group members; (ii) a local file referring specifically to material transactions of the local taxpayer; and (iii) a Country-by-Country Report containing certain information relating to the global allocation of the MNE group’s income and taxes paid together with certain indicators of the location of economic activity within the MNE group.

Related Guidelines

TPG2022 Chapter II Annex I paragraph 1[See Chapter II, Part III, Section B of these Guidelines for general guidance on the application of the transactional net margin method. The assumptions about arm’s length arrangements in the following examples are intended for illustrative purposes only and should not be taken as prescribing adjustments and arm’s length arrangements...
TPG2022 Chapter IV Annex II paragraph 1Advance Pricing Arrangements (“APAs”) are the subject of extensive discussion in the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations at Chapter IV, Section F. The development of working arrangements between competent authorities is considered at paragraph 4.175: Between those countries that use APAs, greater uniformity in APA practices...
TPG2022 Chapter V paragraph 5.60Jurisdictions should require in a timely manner Country-by-Country Reporting from ultimate parent entities of MNE groups resident in their jurisdiction and referred to in Section E.2.2 and exchange this information on an automatic basis with the jurisdictions in which the MNE group operates and which fulfil the conditions listed in...
TPG2022 Chapter V paragraph 5.51It is recommended that all MNE groups be required to file the Country-by-Country Report each year except as follows....
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 5.19The 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 I paragraph 1.32For the foregoing reasons, OECD member countries reiterate their support for the consensus on the use of the arm’s length principle that has emerged over the years among member and non-member countries and agree that the theoretical alternative to the arm’s length principle represented by global formulary apportionment should be...
TPG2022 Chapter V paragraph 5.33A number of countries have introduced in their transfer pricing documentation rules simplification measures which exempt small and medium-sized enterprises (SMEs) from transfer pricing documentation requirements or limit the information required to be provided by such enterprises. In order not to impose on taxpayers costs and burdens disproportionate to the...
TPG2022 Chapter V paragraph 5.61Annex IV to Chapter V of these Guidelines contains an implementation package for government-to-government exchange of Country-by-Country Reports, which includes: • Model legislation requiring the ultimate parent entity of an MNE group to file the Country-by-Country Report in its jurisdiction of residence. Jurisdictions will be able to adapt this model...
TPG2022 Chapter VI Annex I example 926. The facts in this example are the same as in Example 8, except as follows: Under the contract between Primair and Company S, Company S is now obligated to develop and execute the marketing plan for country Y without detailed control of specific elements of the plan by Primair....