Action 13 of the Organisation for Economic Co-operation and Development’s (OECD) final base erosion and profit-shifting (BEPS) report suggested the adoption of a standardized mechanism for transfer-pricing reporting. Per the BEPS report, large multinationals should be required to produce (1) a master file about global business operations and pricing policies available to relevant jurisdictions; (2) a local file, specific to each country, disclosing materially related party transactions and transfer-pricing analyses; and (3) an annual country-by-country (CbC) report of financial results in each jurisdiction with a rundown of group entities and their activities.
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