Master files containing information about business activities of multinational groups, transfer pricing policies and methods of global groups and policies on allocation of income and decentralization of operations and functions in value chains of groups.
Enterprises shall be responsible for retaining and providing the transfer pricing files comprising information, documents, data and records, including:
- Interrelationship and related party transaction information provided in the form given in Appendix I;
- Local files, including information about transfer pricing, transfer pricing policies and methods, prepared and deposited at taxpayers’ offices according to the directory of information and documents prescribed in Appendix II;
- Master files containing information about business activities of multinational groups, transfer pricing policies and methods of global groups and policies on allocation of income and decentralization of operations and functions in value chains of groups according to the directory of information and documents prescribed in Appendix III;
- Country-by-Country reports of profits of ultimate parent companies prescribed in Appendix IV
Content of Master files
Organizational structure
Chart illustrating the MNE’s (multinational enterprise) legal and ownership structure and geographical location of operating entities.
Description of MNE’s business(es)
Important drivers of business profit.
A description of the supply chain for the group’s five largest products and/or service offerings by turnover plus any other products and/or services amounting to more than 5 percent of group turnover, including information about the main geographic markets for these products, services.
The required description could take the form of a chart or a diagram.
A list and brief description of important service arrangements between members of the MNE group, other than research and development (R&D) services, including a description of the capabilities of the principal locations (globally and regionally) providing important services and transfer pricing policies for allocating services costs and determining prices to be paid for intra-group services. A brief description of the main reason in case the group implement marketing service via shopping center and marketing center.
A description of the main geographic markets for the group’s products and services that are referred to in the point 2.2 above.
A brief written functional analysis describing the principal contributions to value creation by individual entities within the group, i.e. key functions performed, important risks assumed, and important assets used.
A description of important business restructuring transactions, acquisitions and divestitures occurring during the fiscal year.
MNE’s intangibles
A general description of the MNE’s overall strategy for the development, ownership and exploitation of intangibles, including location of principal R&D facilities and location of R&D management.
A list of intangibles or groups of intangibles of the MNE group that are important for transfer pricing purposes and which entities legally own them.
A list of important agreements among identified associated enterprises related to intangibles, including cost contribution arrangements, principal research service agreements and license agreements.
A general description of the group’s transfer pricing policies related to R&D and intangibles.
A general description of any important transfers of interests in intangibles among associated enterprises during the fiscal year concerned, including the entities, countries, and compensation involved.
MNE’s intercompany financial activities
A general description of how the group is financed, including important financing arrangements with unrelated lenders.
The identification of any members of the MNE group that provide a central financing function for the group, including the country under whose laws the entity is organized and the place of effective management of such entities.
A general description of the MNE’s general transfer pricing policies related to financing arrangements between associated enterprises.
MNE’s financial and tax positions
The MNE’s annual consolidated financial statement for the fiscal year concerned if otherwise prepared for financial reporting, regulatory, internal management, tax or other purposes; the applicable tax rate determines the tax positions which associate with profits gained from business activities of related parties which have transactions with tax payers.
A list and brief description of the MNE group’s existing unilateral advance pricing agreements (APAs) and other tax rulings relating to the allocation of income among countries.
Contact
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