The master file and local file approach was supposed to bring some consistency to transfer pricing compliance and documentation; however I am finding that there are still local requirements that need to be adhered to. Is a holistic approach to documentation still possible or must we continue to reinvent the wheel in each location that departs from the OECD guidance?
Answer
Yes a global approach is possible but this has been a source of frustration for many businesses. It is important to recognise that transfer pricing regimes fall into the following categories:
those in which a master file and standard local file will be acceptable under domestic regulations;
those in which separate local regulations have been enacted departing from the...
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The master file and local file approach was supposed to bring some consistency to transfer pricing compliance and documentation; however I am finding that there are still local requirements that need to be adhered to. Is a holistic approach to documentation still possible or must we continue to reinvent the wheel in each location that departs from the OECD guidance?
Answer
Yes a global approach is possible but this has been a source of frustration for many businesses. It is important to recognise that transfer pricing regimes fall into the following categories:
those in which a master file and standard local file will be acceptable under domestic regulations;
those in which separate local regulations have been enacted departing from the...
If you are not a subscriber, subscribe now to read this content.
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