OECD Master File concept and CbC Reporting – international ...

Status: Master File concept and CbC Reporting international documentation requirements2 PreambleDear Reader,Due in part to public pressure, the OECD and G20 have adopted a BEPS action plan to counter tax avoidance and profit shifting (BEPS) by multinational corporate groups. To this end, an action plan was published in April 2013, providing 15 action points on which measures are to be developed and implemented in order to achieve the goal of preventing tax-aggressive of these action points dealt directly with transfer pricing issues. After the final report on Action 13 ( Transfer Pricing Documentation and Country-by-Country Reporting ) was published by the OECD in 2015, the three-tiered documentation approach consisting of Master File, Local File and Country-by-Country Reporting can now be found in the OECD Transfer Pricing Guidelines of July 2017.

against Base Erosion and Profit Shifting of multinational enterprises, countries implemented these actions as far as possible via changes in domestic law and practices and via treaty provisions in order to protect their respective national tax bases. The BEPS Action Point 13 („2015 Final Report – Transfer Pricing

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  Provisions, Shifting

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