Understand the essentials that turn compliance from a burden into a strategic shield for your international growth.
Master File
This is the strategic blueprint of your entire multinational group. It explains your global business model, where your value is created, and your transfer pricing policies. It moves the discussion away from individual invoices and provides a cohesive, universal narrative.
This is the key to preventing your global transactions from becoming an ‘audit magnet.’ Want to know exactly why and what to include?
Local File
The Local File is the specific proof. Prepared for each jurisdiction, it details the local entity’s transactions, financial data, and the application of the group’s transfer pricing policies. This includes crucial benchmarking studies to demonstrate that prices meet the arm’s length standard.
Local tax authorities want hard evidence. How do you prove your internal prices are fair and avoid costly local adjustments?
“Confidential” CbCR
The Country-by-Country Report (CbCR) is a confidential template exchanged between tax authorities. It gives them an aggregated, high-level overview of the group’s key financial metrics, taxes paid, and the location of economic activity (employees, assets) in every jurisdiction.
This is the Tax Authority’s primary risk assessment tool. What red flags are they looking for in your numbers, and how can you proactively address them?
Public CbCR
A recent requirement, the Public CbCR mandates that the core CbCR data (revenue, profit, tax paid) for EU and associated countries be made public. This shifts compliance from a private matter to a public transparency and reputational issue for large multinational enterprises.
Your tax strategy will be visible to the public, media, and competitors. How do you ensure your tax story is defensible, not just to the Tax Authority, but to the world?
Ready to make your international structure audit-proof?
We provide the deep technical knowledge and strategic insight to move you from compliance anxiety to strategic control.