Master File Transfer Pricing. Transfer pricing rules apply in respect of transactions relating to assets that have a market value of over 25 million or where the capital expenditure incurred on an asset is over 25 million. The master file provides a high level overview of the mne groups global business structure and activities.
In general the master file is intended to provide a high level overview in order to place the. It is a group wide document that should be made available on request or submitted annually which sets out key qualitative economic analysis of the group. Action 13 significantly increases transparency over multinational taxpayers.
The local file provides detailed transactional transfer pricing documentation.
The oecd recommended that the master file and local file elements of the standardised approach should be implemented through domestic legislation or administrative procedures. Within 30 days notice master file and. The local file provides detailed transactional transfer pricing documentation for a specific jurisdiction identifying material related party transactions the amounts involved and the companys transfer pricing analysis of those transactions. Pwcs transfer pricing series master file local file.