Global Transfer Pricing Country Requirements
Thresholds, deadlines, penalties, and the documents each jurisdiction requires: reviewed individually for 110 countries.
01 The three-tiered standard
Most contemporary transfer pricing documentation rules grew out of the OECD and G20 Base Erosion and Profit Shifting project. Its work on Action 13, finalised in 2015, rewrote the documentation chapter of the OECD Transfer Pricing Guidelines and introduced a layered approach built on three documents: a Master File, a Local File, and a Country-by-Country report. Many jurisdictions have since written some version of this structure into domestic law, but the way each layer is implemented differs considerably from one country to the next.
The three documents are designed to be read together. The Master File supplies the global context, the Local File carries the entity-level detail and the arm’s length analysis, and the Country-by-Country report offers a high-level financial picture of the group spread across the jurisdictions where it operates. Because tax authorities can cross-check one against another, a group whose three documents tell inconsistent stories invites scrutiny. All three are refreshed each year, and in most countries the Master File and Local File have to be ready by the time the annual tax return is filed.
What often surprises taxpayers is that the three layers do not necessarily appear together. Country-by-Country reporting is a defined standard with one widely shared trigger, but the Master File and Local File are not, so a country may require one and not the other, may bolt on a separate documentation duty that runs alongside the Local File, or may demand documentation without ever using the Master File or Local File labels. The country pages in this library preserve those differences rather than collapsing them into a single template.
02 What each tier contains
The group-wide overview. It covers how the group is structured, what its businesses do and what drives their profitability, how it develops and holds intangibles, how it finances itself internally, and where it stands financially and for tax, including consolidated accounts and any rulings affecting how income is split between countries. The same version is shared with every authority, so groups keep it consistent.
The entity-level document. It focuses on the local taxpayer’s significant related-party dealings, the sums involved, and the reasoning showing those dealings were priced at arm’s length. It holds the functional analysis, the chosen method, and the benchmarking study, and is the file an auditor tests most closely. Its scope is set by local law, so thresholds and depth vary widely.
The group’s financial map. Filed by the ultimate parent with its own tax authority and exchanged internationally, it reports revenue, pre-tax profit, tax, capital, earnings, headcount, and assets for each jurisdiction. It is aimed at the largest groups and used only for high-level risk assessment. The shared trigger is consolidated revenue of EUR 750 million, or a local-currency figure close to it.
Browse 110 countries
Chips show which obligations apply. Each page notes when it was last reviewed.Europe, Middle East & Africa
64 countriesAmericas
22 countriesAsia-Pacific
24 countriesNo country matches that search.
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