In this short article, we explain what the Master File is and when you need to create one. We also give an overview of the items that need to be included.
If you’re looking for more information on the implications of transfer pricing on Mergers and Acquisitions, you’ve come to the right place. It is absolutely important to consider transfer pricing before closing any M&A deal. This can help you to negotiate a better deal and/or avoid financial surprises after the deal is done!
Before we continue, it is important to understand that the main purpose of transfer pricing rules is to examine the ‘arm’s-length’ nature of ‘controlled transactions’. If these terms don’t ring a bell, we advise you to first read our article What is transfer pricing?
In this short article, we explain what the Local File is and when you need to create one. We also give an overview of the items that need to be included in the Local File.
Please note that the Local File is just one part of the documentation requirements that apply to MNEs. You can read more in our general article on transfer pricing documentation.
This article answers the question: what is transfer pricing documentation?
First, we explain why transfer pricing documentation exists. After that, we look at the goals of the current documentation requirements. Finally, we explain the three different reports that together form a full set of transfer pricing documentation.
If you are looking for more information on the Profit Split Method, this article is for you.
Below, we explain this transfer pricing method in more detail, provide an example and explain when and how you can use it.