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Home / Simons-Taxes /Business tax /Part B4 Transfer pricing and profit fragmentation /Division B4.1 Transfer pricing /Transfer pricing documentation / B4.160 Transfer pricing documentation—OECD guidance
Commentary

B4.160 Transfer pricing documentation—OECD guidance


Business tax

Three tiered approach to transfer pricing documentation

The recommended OECD approach is a three-tiered structure consisting of1:

  1. Ìý

    •ÌýÌýÌýÌý a master file containing standardised information relevant to all the multinational enterprise (MNE) group members

  2. Ìý

    •ÌýÌýÌýÌý a local file which documents material transactions of the local taxpayer

  3. Ìý

    •ÌýÌýÌýÌý a country-by-country report containing information relating to the global allocation of the MNE's income and taxes (see B4.162)

Master file

The master file should provide a high level overview of the MNE's global operations and policies in

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