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Implementation status: OECD Master File concept and CbC-Reporting


Updated on 16 April, 2020


The public’s focus surrounding international tax matters has increased consistently in recent years and has never been stronger than its current state. The Base Erosion and Profit Shifting (“BEPS”) Project was initiated by the OECD and G20 to combat perceived profit shifting activities and represents an organized effort to establish an effective framework to deal with ever-increasing global tax challenges.


More precise and useful information for transfer pricing risk assessments and audits

BEPS Action 13 deals with enhancing transparency for tax administrations by providing them with adequate information to assess high-level transfer pricing (“BEPS Action 13: Re-examine Transfer Pricing Documentation”). The three-level approach comprising Master File, Local File and Country-by-Country Reporting has now been made an integral part of the new OECD Transfer Pricing Guidelines of 17 July 2017.


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International duty to cooperate as important compliance task

In view of the transfer pricing documentation and country-specific reporting obligations regulated on national level, it is hardly surprising that the process of determining individual reporting obligations binding on internationally operating groups will itself take a lot of effort and give rise to uncertainty in some cases. However, knowledge of the implementation status in the respective country is an important compliance task for the transfer pricing management within international corporate groups, in particular in order to avoid formal errors, and thus a first point of criticism regarding the usability of documentation.


OECD Master File Concept and CbC Reporting – international documentation obligations 

To offer companies an insight into the national implementation of the OECD Master File concept and CbC Reporting in different countries, the international transfer pricing group of Rödl & Partner has prepared a bilingual overview of more than 60 countries. The aim of this publication is to offer you guidance. In case of any questions please do not hesitate to contact us.




English Version »

German Version » 


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