Updated: Sep 14, 2022
The Master File is intended to provide tax administrations with an overview of the economic, legal, financial and tax arrangements within an MNE.
Simply put, it is a 360-degree look at the company’s global transfer pricing operations and policy.
The information required is divided into five categories:
1. MNE's Organisational Chart
A diagram depicting the legal and ownership structure of the MNE, as well as the geographical location of its functioning businesses.
2. A general description of the MNEs' Business (es)
Important drivers of business profit
A description of the supply chain for the group’s 5 most significant products and/or service offerings by turnover plus any other products and/or services amounting to more than 5% of group income;
A list and a brief description of essential service arrangements between members of the MNE group, other than research and development (R&D) services;
A description of the main geographic markets
A functional analysis that outlines the primary contributions to value creation made by individual entities that are part of the group, such as the main functions that are carried out, the essential risks that are assumed, and the important assets that are utilised;
A description of important business restructuring transactions, acquisitions and divestitures
3. MNE's Intangibles Assets
Notable intangible assets or categories of intangible assets, and which organisations are their owners;
General description of the MNEs' overall strategy for the development, ownership and exploitation of intangibles, group’s transfer pricing policies related to R&D and intangibles etc.
4. MNE's Intercompany Financial Transactions
Intra-Group financing arrangements and major financing arrangements with unrelated parties
A general description of how the group is financed, including important financing arrangements with unrelated lenders
5. MNE's Financial and Tax Position
A list and a brief description of the MNE group’s existing unilateral advance pricing agreements (APAs) and other tax rulings relating to the allocation of income among countries
利润的重要价值贡献因素，营业收入位居前 5 位以及占营业收入总额超过 5% 的集团产品或者劳务
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6. LinkedIn ✍ https://www.linkedin.com/company/74734209/admin/