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Transfer Pricing > Master File

Transfer Pricing

Master File

The Master File (MF) 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, in order to allow administrations Taxes that 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 is intended to provide a high-level overview in order 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.