Master File — Group-Level TP Documentation (OECD BEPS Action 13)

The Master File is the first tier of the three-tiered transfer pricing documentation approach under OECD BEPS Action 13. It gives tax administrations a high-level overview of the multinational group’s worldwide business activities, organisational structure, value chain, intra-group transactions, and group-level financial data.

• Organisational structure: Legal structure, ownership, geography
• Business description: Key value drivers, supply chains, service arrangements, functional analysis, business restructurings
• Intangibles: Strategy, list of important intangibles, R&D activities
• Intra-group financing: Key financing arrangements, central cash-pooling structures
• Financial and tax position: Consolidated financial statements, existing APAs and tax rulings

The Master File was introduced by BEPS Action 13 (2015), replacing or supplementing previously divergent national documentation requirements. The underlying concept draws on the EU Transfer Pricing Documentation Code of Conduct (Resolution 2006/C 176/01) of the Joint Transfer Pricing Forum (JTPF, 2006), which included an analogous masterfile concept. Implementation into national law took place in most OECD states between 2016 and 2018.

In July 2017, the BEPS Action 13 outcomes were integrated into the OECD Transfer Pricing Guidelines. In January 2022, a consolidated edition of the Guidelines was published, merging all previous revisions. Additionally, in February 2024 the Amount B framework was released, providing simplified transfer pricing approaches for certain baseline distribution transactions.

The Master File is recommended as best practice by the OECD Transfer Pricing Guidelines and is legally required in many jurisdictions that have implemented BEPS Action 13 — however, it is not part of the BEPS minimum standard, which covers only CbCR. The revenue threshold for CbCR is EUR 750 million of consolidated group revenue in the EU (DAC4/Directive 2016/881) and many other states; Master File and Local File thresholds are set at the national level and frequently differ from the CbCR threshold. The Master File is prepared centrally by the parent and must be filed locally or made available on request.

• Description of the group’s organisational structure (legal form, ownership)
• Description of the group’s major business lines and value chains
• List of important intangible assets and their owners
• Description of intra-group financial activities
• Group consolidated financial statements
• Existing APAs and tax rulings relating to income allocation

2 corrections:
- DAC4 incorrectly described as establishing Master File obligation
- DAC4 date incorrect: 25 May 2016, not 25 June 2016
2 updates:
- Missing key_dates: TP Guidelines 2017 and 2022
- Missing mention of 2022 consolidation and Amount B
7 clarifications.
2 notes.