TPG2022 Chapter V paragraph 5.20

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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.

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