The Master File is a key international tax document and one of three tiers for Transfer Pricing documentation required for Multinational Enterprises (MNEs) as laid down by the OECD’s Base Erosion and Profit Shifting (BEPS) Action Point 13 framework to counter tax evasion. The Master File contains standardized information for all MNE group members. It provides a general overview of the MNE group’s business including all intra group pricing arrangements in global financial, legal and tax terms. The Master File is related to the heart of the international tax system and hence vitally important for MNE businesses.
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