Transfer Pricing Documentation
Article explains Applicability of Master File, Master File– Forms and Timelines, Applicability of CbCR, CbCR – Forms and Timelines and Important Terms related to Transfer Pricing (Accounting Year, Constituent Entity, Alternate Reporting Entity & International Group).
Three-tier transfer pricing documentation structure:
1. Local File- This needs to be documented with the Company itself.
2. Master File- Needs to be filed with IT Department.
3. Country by Country Report– Needs to be filed with IT Department.