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Master File

The Master File collects standardized information at the business group level, including the nature of its global operations, its transfer pricing policies, and the distribution of its benefits and economic activities worldwide to allow tax administrations to assess whether there is a significant risk of transfer pricing.
 
According to the Transfer Pricing Guidelines of the OECD (Organization for Economic Cooperation and Development), the master file aims to provide a high-level overview to locate the transfer pricing practices of the multinational group in its global economic, legal, financial, and fiscal context.
 
We provide support for compliance with the minimum information that must be contained in the Master File, which contains relevant data that can be grouped into five categories:
  • Organizational structure of the business group
  • Description of the business from all the group
  • Intra-group financial activities
  • Financial and tax positions of business group entities
  • Intangibles of the business group.
Return to Transfer Pricing

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We put at your disposal the best local and international support to deal with the different financial situations of our clients in the different corporate areas of a Company with local or foreign capital.

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