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Country File, Master File and CbC Reporting

VVA EO has developed a significant experience in assisting its clients in drafting and filing TP Country and Master Files. TP Documentation is not mere compliance, as it constitutes the ‘image’ that a MNE provides of itself to the tax authorities.


This concept is remarkably enforced by the new three-tiered standardised approach to transfer pricing documentation introduced by Action 13 within the OECD BEPS Project (implemented in the OECD TP Guidelines in July 2017).


Under this new regime, which is being increasingly adopted in local regulations, starting from the financial year 2016 taxpayers are required to draft three documents:


  • The Master File, which provides all relevant tax administrations with high-level information regarding global business operations and the group transfer pricing policy;
  • The Country (Local) File, specific to each country, identifying material intra-group transactions, the amounts involved in those transactions and the analysis of the group TP policy; and
  • The Country-by-Country Report (CbCR), drafted on a yearly basis and for each tax jurisdiction, providing for the amount of revenue, profit before income tax, income tax paid and accrued, number of employees, stated capital, retained earnings and tangible assets. CbCR is mandatory for MNEs reporting consolidated revenues higher than €750 million.


This set of documents provides tax authorities with useful information to identify practices (either TP or other tax practices) allowing the artificial shift of income.


VVA EO is already advising several clients required to comply with the new TP Documentation regime, also through the coordination of local subsidiaries and local tax advisors to grant overall consistency of the documentation.