Taxpayers should present the information in the master file for the MNE group as a whole. However, organisation of the information presented by line of business is permitted where well justified by the facts, e.g. where the structure of the MNE group is such that some significant business lines operate largely independently or are recently acquired. Where line of business presentation is used, care should be taken to assure that centralised group functions and transactions between business lines are properly described in the master file. Even where line of business presentation is selected, the entire master file consisting of all business lines should be available to each jurisdiction in order to assure that an appropriate overview of the MNE group’s global business is provided.
TPG2022 Chapter V paragraph 5.20
Posted on |
By OECD
Category: OECD Transfer Pricing Guidelines (2022), TPG2022 Chapter V: Transfer Pricing Documentation | Tag: Master file, Transfer pricing documentation
« Prev |
Next » Related Guidelines
- 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 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 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 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 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 VI Annex I example 1654. Shuyona is the parent company of an MNE group. Shuyona is organised in and operates exclusively in Country X. The Shuyona group is involved in the production and sale of consumer goods. In order to maintain and, if possible, improve its market position, ongoing research is carried out by...
- 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 5.61Annex 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 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...