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The OECD’s White Paper on Transfer Pricing Documentation takes stock of the existing approaches to harmonising transfer pricing documentation, but goes considerably further by proposing a coordinated approach to documentation based on a two-tier structure. Building on the EU’s TPD, the paper advocates the creation of a global masterfile giving important information about a company and its intangible assets that is complemented by a local country and transaction-specific file of local country documentation.
This would significantly enhance transparency while increasing standardisation of the treatment of intangibles.
Read our report for further detail.
