Transfer Pricing Documentation – Master File

The Master File is a key component of transfer pricing reporting for multinational groups operating across multiple jurisdictions. It is required under both Polish regulations and the OECD Guidelines (BEPS Action 13).

The Master File provides a comprehensive overview of the entire group, including its business model, organisational structure, value chain, transfer pricing policies, and the allocation of functions, assets and risks at a global level. Its purpose is to give tax authorities a coherent and transparent understanding of where and how value is created within the group, which entities perform key functions, and how intra-group transactions are managed across countries.

As part of the service, we prepare:

1. Identification of Master File requirements and group structure analysis: verification of whether the entity meets the thresholds for preparing a Master File (local rules / OECD), identification of the parent entity and subsidiaries across jurisdictions, determination of the scope of group-level data required for documentation, review of available materials from headquarters (e.g., global TP policies, investor presentations, annual reports, organisational charts).

‍2. Group description (OECD – BEPS Action 13, Chapter V): we prepare a comprehensive operational and strategic overview of the group, including: description of the group’s business profile and key business lines, global organisational and ownership structure, overview of geographic markets in which the group operates, description of the competitive and regulatory environment, information on group strategy, governance model and central functions. This section fully complies with the OECD requirements for the Group Overview.

‍3. Description of intangibles and the value chain (DEMPE): in accordance with OECD Guidelines, we prepare: description of key intangibles within the group (IP, technologies, patents, know-how, brand, software), DEMPE analysis (development, enhancement, maintenance, protection, exploitation), identification of entities responsible for creating and managing IP, overview of licensing policies and intra-group arrangements involving intangibles, mapping of value flows and remuneration associated with IP across the group.

‍4. Description of financial transactions and group financing structure: based on OECD and local requirements, this includes: description of the group’s financing policy (loans, guarantees, cash-pooling, hedging), model for liquidity and financial risk management, information on external and intra-group financing, key economic indicators and financial risks at group level, the role of central treasury or financing units.

‍5. Description of the group’s transfer pricing policy: we prepare: overview of TP methods applied within the group (CUP, TNMM, RPM, Cost Plus, Profit Split), justification for the selection of methods in line with OECD Guidelines, description of settlement principles between group entities, information on benchmarking studies used in the group, mapping of transactional relationships across the group.

‍6. Financial information and the group’s value creation model: the documentation includes:description of profit allocation and functions across group entities, analysis of the value chain and identification of key value-creation locations, identification of key value-driving assets and their impact on group EBIT.

‍7. Preparation of the Master File in accordance with local and OECD requirements: we deliver a complete Master File including: description of the group (strategy, operating model, value chain), description of intangibles and DEMPE policies, description of the financing policy, transfer pricing policy and intra-group settlement principles, group documents, charts, organisational structures, decision-making processes, integration with the Local File and CbCR. Typical length: 50–80 pages + appendices.

‍8. Support with CbCR and tax audit processes: preparation of data and verification of consistency between Master File and the CbC Report, support during international audits and tax inspections, coordination with headquarters and local tax teams, recommendations for implementing TP policies across the group.

‍Client outcome: a Master File prepared by our team: complies with local and OECD requirements, enabling use in all jurisdictions where the group operates, provides a coherent and complete presentation of the group’s operational and financial model, minimises tax risks and ensures alignment with the global TP policy, facilitates preparation of Local Files, CbCR and local disclosures, organises corporate documentation and internal processes, serves as a robust basis in audit processes and tax dispute situations.