Plain English
One document, written once, shared with every country that asks. It describes the group's structure, what drives its profits, where its IP sits, and how it finances itself. It is deliberately high level — the detail belongs in the local file.
Technical definition
The first tier of the three-tiered documentation standard under BEPS Action 13, containing standardised information on the group's organisational structure, description of business, intangibles, intercompany financial activities, and financial and tax positions.
Why it matters
It is the document that frames how an examiner reads everything else. Inconsistency between the master file and local files is a common audit trigger.
How it works in practice
- 01Collect group-level inputs: structure chart, value drivers, IP register, financing overview.
- 02Draft once centrally; translate as required locally.
- 03Align narrative with the local files and CbC report before filing.
- 04Refresh annually.
Worked example
Consistency check
A master file describes R&D as centralised in Switzerland. A local file in Poland describes the Polish entity as performing significant product development for the group. That contradiction alone can open a DEMPE enquiry in both countries.
Common mistakes
- Copying prior-year text without checking the business has not changed.
- Describing aspirational operating models rather than actual ones.
- Missing local filing or notification deadlines.
Audit red flags
- Master file value chain that does not mention a material business line.
- IP list that omits recently acquired intangibles.
Documentation & data
Documents to hold
- Group structure chart.
- Value driver description.
- List of important intangibles and related agreements.
- Group financing arrangements and consolidated financial statements.
Data you need
- Consolidated accounts.
- Group IP register.
- Intercompany agreement inventory.
Who owns this internally: Group tax, centrally.
Jurisdiction notes
- European Union
- Adoption is widespread but thresholds and deadlines differ by member state; some require local language versions.
- Asia-Pacific
- Several jurisdictions require the master file to be filed rather than merely maintained.
Notes by role
In-house tax teams
Run a consistency pass across master file, local files and the CbC report before any of them is filed. It takes a day and prevents years of questions.
Frequently asked
- Who has to prepare a master file?
- Thresholds are set domestically, often linked to group revenue. Many jurisdictions align with the CbC reporting threshold of EUR 750 million, but plenty apply lower local thresholds.
Sources & status
- Primary source
OECD Transfer Pricing Guidelines, Chapter V and Annex I
OECD, 2022
- Primary source
BEPS Action 13 Final Report
OECD, 2015
Reference material only, not advice on a specific fact pattern. Reviewed 2026-06-30.
Careers
How this shows up in the job
Documentation cycles are how most people learn a group's business fast. Volunteer for the master file refresh.
Careers in transfer pricing