Operations & compliance
Master file
The master file is the top-level document in the OECD's three-tier transfer pricing documentation structure, providing a group-wide overview of the business, its organisational structure, intangibles, financing arrangements and overall transfer pricing policies, so tax authorities in every country can see the bigger picture.
A well-prepared master file describes the group's supply chains, key value drivers, and how intangibles are developed, owned and exploited across the business, giving tax authorities the context needed to assess whether local entity results are consistent with the functions and risks each entity actually carries.
Because the master file is shared across every jurisdiction the group operates in, consistency really matters, and any description that conflicts with what a local file or country-by-country report says about the same entity will draw immediate attention from whichever tax authority spots the discrepancy first.
In practice
What matters when applying master file
- Describe the group's overall value chain
- List key intangibles and their ownership
- Summarise group financing arrangements
- Keep descriptions consistent across all files
- Update annually alongside local files
Frequently asked
Common questions
Who needs to prepare a master file?+
Groups above the relevant revenue threshold, typically set locally but often aligned with the OECD's EUR 750 million benchmark, are generally required to prepare a master file. This matters in practice.
How does the master file differ from the local file?+
The master file gives a group-wide overview of the business and policies, while the local file focuses on the specific intercompany transactions of one entity in one country. This matters in practice.
See how the tooling handles this in practice
Our transfer pricing tools calculate intercompany charges, benchmark financing and reconcile the intercompany ledger from your own data. Book a short walkthrough and we will show the workflow on a scenario that matches your group structure, rather than a generic demo dataset.