Ensure your global transfer pricing obligations are met accurately and on time. We handle all statutory filings with a consistent, compliant, and audit-ready approach.
Master File
A Master File provides a consolidated overview of your group’s global business, value chain, intangibles, financing arrangements, and transfer pricing policies. It is required under BEPS Action 13 for multinational groups operating across multiple jurisdictions and ensures that tax authorities receive a clear, consistent global narrative.
What we do:
- Document value chain narratives, DEMPE functions, intercompany arrangements, and TP methodologies.
- Draft clear, consistent Master Files aligned with your operating model and regulatory expectations.
- Ensure alignment between the Master File, Local Files, and group TP policy.
Our experience:
- Preparing Master Files for listed multinationals, high-growth software, fintech, and health-tech companies, and global scale-ups.
- Supporting documentation needs across Europe, Asia, North America, and emerging markets.
Local File
The Local File is a jurisdiction-specific document required annually to demonstrate that local related-party transactions are priced at arm’s length. Companies need a Local File whenever they have material intercompany transactions or operate in countries with mandatory TP documentation laws—making it the foundation of audit defence.
What we do:
- Prepare jurisdiction-specific Local Files reflecting local functions, assets, risks, and regulatory rules.
- Align Local Files with the Master File and group TP policy for consistency.
- Incorporate country nuances including Poland’s detailed disclosure requirements, Australia’s strict documentation standards, and India’s in-depth FAR expectations.
Our Experience:
- Preparing Local Files across 68+ jurisdictions including the UK, Switzerland, Germany, Poland, Australia, Japan, the USA, Mexico, China, and India.
- Supporting entities across distribution, services, technology, manufacturing, and financial sectors
Country-by-Country Reporting (CbCR)
CbCR is an annual filing required under BEPS Action 13 that provides tax authorities with a high-level profile of global income, taxes paid, and economic activity. Groups exceeding revenue thresholds must file CbCR to meet transparency requirements and to manage early-stage TP or Pillar Two risks.
What We Do
- Prepare compliant CbCR reports with validated, reconciled datasets and accurate jurisdiction-wise disclosures.
- Implement regulatory updates and ensure filings align with OECD and local rules.
- Conduct consistency checks between CbCR, Pillar Two (GloBE), and local reporting frameworks.
Our Experience
- Managing CbCR filings since their introduction in both in-house and advisory roles.
- Supporting groups with data mapping, XML schema preparation, surrogate filing decisions, and statutory reconciliations.
Country-Specific Filings
Many jurisdictions require mandatory transfer pricing forms, disclosures, declarations, and TP-related statutory filings separate from the Master File, Local File, or CbCR. These filings are needed annually and vary widely across countries such as India, Mexico, Malaysia, Poland, Japan, Australia, and the UK.
What We Do
- Prepare and support country-specific TP filings example Form 3CEB (India), SIT TP Forms (Bangladesh), CIT disclosures, and jurisdiction-required declarations.
- Ensure consistency between statutory TP forms and the underlying Master File, Local File, benchmarking, and intercompany policies.
Our Experience
Supporting multinational groups with TP forms and disclosures across Europe, Asia-Pacific, and the Americas.