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TP FAQs 1: What does "Three-Tiered Approach" to Transfer Pricing Documentation mean?

Updated: Sep 15, 2022

转让定价同期资料 [Contemporaneous Transfer Pricing Documentation] 概念,源自于20世纪 90 年代初期的美国。

纳税人在与关联方进行交易前或交易时确定关联方交易定价所依赖的文件和信息被称为 "同期转让定价文件"。

为了打击 "税基侵蚀和利润转移" (Base Erosion and Profit Shifting,简称 “BEPS”),经济合作与发展组织(The Organisation for Economic Co-operation and Development,简称 “OECD”)及二十国集团(英语:Group of Twenty,缩写:G20)在2013年合作制定了一个15点行动计划。


  • "BEPS行动13:重新审查转移定价文件"

The concept of Contemporaneous Transfer Pricing Documentation originated in the United States in the early 1990s.

Documentation and information that taxpayers have relied upon to determine the pricing of a related party transaction before or at the time of undertaking the transactions with related parties are referred to as "contemporaneous transfer pricing documentation."

To combat "Base Erosion and Profit Shifting," sometimes known as "BEPS," the OECD and the G20 countries collaborated in 2013 to produce a 15-point Action Plan.

The documentation of the transfer pricing was the subject of one of these actions, which was referred to as

  • "BEPS Action 13: Re-examine Transfer Pricing Documentation."

BEPS Action 13 Guidance Implementation TP Documentation CbCR
Download PDF • 547KB

三层结构 | Three-Tiered Structure


To be able to reach the aims mentioned above, the countries should adopt a standardised approach to transfer pricing documentation that includes the three-tiered structure encompassing a Master file, a Local file, and a Country-by-Country Report ("CbC Reporting") to be able to reach the goals that were outlined above.

Three-Tiered Approach to Documentation

主体文档 | Master File





  • 组织结构

  • 一项或多项业务的描述

  • 无形资产

  • 公司间财务活动

  • 财务和税务状况

An overview of an MNE's global operations, its overall transfer pricing policies for the creation and ownership of intangibles, its financial activities, and its global allocation of income and economic activity should be included in the master file.

This will allow the transfer pricing practices of the MNE to be placed in the global economic, legal, financial, and tax context.

MNEs should exercise good judgement while generating the master file to decide the appropriate level of detail.

This is particularly important when taking into mind the fact that the OECD guidelines state it is not required for the master file to include detailed details. However, there is also cause for concern that the information on local transactions may affect the perspective that a particular tax authority has of what constitutes reasonable business judgement.

The required information can be grouped into five categories:

  • The MNE organisational structure

  • A description of the MNE’s business or businesses

  • The MNE’s intangibles

  • The MNE’s intercompany financial activities

  • The MNE’s financial and tax positions

本地文档 | Local File


与主体文档一样,BEPS 为本地文档中应包含的信息提供了指导方针:

  • 本地实体的管理结构

  • 在纳税年度内所执行的公司内部交易

  • 相关公司间的协议

  • 转让定价的方法和应用

  • 本地实体的财务状况


  • 组织结构

  • 集团财务报告

  • 业务/行业的性质和市场条件

  • 受控交易

  • 定价政策

  • 有关影响定价政策制定的因素的假设、策略和信息

  • 职能分析

  • 可比性分析

  • 转让定价方法的选择和应用

The Local File includes information on the intracompany transactions within the local company.

In the same way, as with the Master File, the BEPS provides guidelines for the information that should be included in local files:

  • The management structure of the local entity

  • Intracompany transactions executed during the tax year

  • Related intercompany agreements

  • Transfer pricing methodology and application

  • Local entity financials

While the Master File offers a high-level summary, however, the Local File provides more in-depth information concerning particular significant intercompany transactions; referring to The Malaysian Transfer Pricing Guidelines 2012, key elements include:

  • Organisational Structure,

  • Group financial report

  • Nature of the business/industry and market conditions

  • Controlled transactions,

  • Pricing policies.

  • Assumption, strategies and information regarding factors that influenced the setting of pricing policies

  • Functional Analysis,

  • Comparability Analysis,

  • Selection and Application of Transfer Pricing Methods.