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Transfer Pricing Master File Template (OECD Chapter V Annex I)

OECD-style master file: org chart, value drivers, supply chains, functional analysis, intangibles (DEMPE), financing, APAs, TP policies, UK/US/VN/DE cross-reference

財務・投資・会計フルOECD Transfer Pricing Guidelines 2022, Chapter V Annex I; UK SI 2023/818; Vietnam Decree 255/2026/ND-CPtransferpricingmasterfile

使い方: Use it when your multinational group must document its transfer pricing at group level for several tax authorities. Fill the jurisdiction table and entity list first, then the functional analysis and the policy summary that every local file reuses. The main pitfall is a master file whose functional story contradicts the local files or the CbC report.

プレビュー

Transfer Pricing Master File: [MNE group name] FY[YYYY]

Group-level transfer pricing documentation (the "master file") for a multinational enterprise (MNE) group: organisational structure, business description and value drivers, supply chains, intangibles, intercompany financing, financial and tax positions, and the group's transfer pricing policies. Structure follows the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, Chapter V, Annex I, with a cross-reference to local rules in the United Kingdom, the United States, Vietnam and Germany (as of 2026-10). Replace every [bracketed] value and every row marked Example. This is a document format, not tax, legal, accounting or financial advice. Requirements are referenced by number: obtain the guidelines or the law for the normative text.

Document control

FieldValue
Document ID[TP-MF-FY2026]
Version[1.0]
Status[Draft / In review / Approved / Superseded]
MNE group and ultimate parent entity[Group name], [UPE legal name, jurisdiction] Example: Ostrander Group, Ostrander Group N.V. (Netherlands)
Financial year covered[YYYY-MM-DD to YYYY-MM-DD] Example: 2026-01-01 to 2026-12-31
Reporting currency and units[EUR thousand]
Accounting framework of consolidated statements[IFRS / US GAAP / other]
Owner[@head-of-tax]
Prepared by[@transfer-pricing-manager], [External adviser, if any]
Approvers/reviewers[@cfo], [@group-controller], [@legal-counsel], [@local-finance-leads]
Last updatedYYYY-MM-DD
Classification[Confidential: tax authorities and authorised staff only]
Language versions[English master; translations listed in section 9]
Related local files[TP-LF-NL-FY2026], [TP-LF-DE-FY2026], [TP-LF-UK-FY2026], [TP-LF-US-FY2026], [TP-LF-VN-FY2026]
Related CbC report[CBCR-FY2026]

Approvals

RoleNameDecisionDate
Head of Tax[@name][Approve / Return]YYYY-MM-DD
Chief Financial Officer[@name][Approve / Return]YYYY-MM-DD
Legal counsel (entity and agreements facts)[@name][Confirm / Return]YYYY-MM-DD
External adviser review (optional)[Firm, @name][Reviewed]YYYY-MM-DD

Revision history

VersionDateAuthorChange
0.1YYYY-MM-DD[@author]First draft from prior-year file and FY data request
0.9YYYY-MM-DD[@author]Functional interviews and intangibles section updated
1.0YYYY-MM-DD[@author]Approved after CFO review

Contents

1. Purpose, scope and legal basis

1.1 Purpose

This master file describes the [Group name] group as a whole for the financial year [YYYY]. It explains the business, the allocation of functions, assets and risks among group entities, the intangibles and financing that drive profit, and the policies used to price transactions between group entities under the arm's length principle. It is the common reference for every local file and for the country-by-country report.

Example: Ostrander Group sells a cloud storefront and order management platform to merchants on a subscription basis (subscription segment), sells hardware and consumables for point-of-sale use (commerce segment), and provides onboarding and integration work (services segment). The Dutch parent owns the platform and brand and bears the main business risks; the German, UK and US companies distribute the group's offering in their markets; the Vietnamese company develops software for the parent under a contract research and development arrangement.

1.2 Jurisdiction requirements (as of 2026-10)

Check local law before relying on this table: thresholds, deadlines and languages change, and several countries add items beyond the OECD list.

JurisdictionLegal basis (as of 2026-10)Who must keep a master fileTimingApplies to Ostrander FY2026?
United KingdomTransfer Pricing Records Regulations 2023 (SI 2023/818)UK entities of MNE groups with consolidated revenue of at least EUR 750m; accounting periods beginning on or after 2023-04-01Keep the master file and local file in OECD format; produce within 30 days of an HMRC requestYes: group revenue is above EUR 750m, so Ostrander UK Ltd keeps both files (Example)
United StatesIRC section 6662(e) and Treas. Reg. 1.6662-6(d)(2)(iii)No master file format; documentation is needed for penalty protectionTen principal documents in existence when the return is filed; provide within 30 days of an IRS requestYes, as penalty-protection documentation for Ostrander Inc; the master file supplies the business overview and organisation chart (Example)
VietnamDecree 255/2026/ND-CP (replaced the previous transfer pricing decree from 2026-07-01; applies from the 2026 corporate income tax period)Taxpayers with related-party transactions, unless an exemption applies (exempt if revenue is below VND 500bn, there is no revenue or cost from exploiting intangibles, and the net margin is at least 5% for distribution, 10% for manufacturing or 15% for processing; the former simple-function condition is removed)Prepare before the corporate income tax finalisation return; provide on request within the period set by the decree (confirm)Yes: Ostrander Vietnam revenue is about VND 3,751.7bn, far above the exemption threshold (Example)
GermanySection 90(3) AO and the Profit Allocation Records Regulation (GAufzV)Entities belonging to an MNE group whose own revenue in the previous financial year was EUR 100m or more must keep a master file (Stammdokumentation); every entity keeps a transaction matrix (Transaktionsmatrix) and local documentationSubmit within 30 days of a request; in a tax audit, the transaction matrix, master file and records of extraordinary transactions are due within 30 days of the audit order without separate requestYes: Ostrander Deutschland GmbH revenue of EUR 191,000k in the previous financial year (FY2025) exceeds EUR 100m (Example)
NetherlandsCorporate Income Tax Act 1969 (Wet Vpb), articles 29g and 29h, with the implementing decree (check)Dutch entities of MNE groups with consolidated revenue of EUR 50m or more in the preceding year keep a master file and local file (check the threshold)Files in the entity's administration by the corporate income tax return filing date (check)Yes: OST-NL as parent and principal (Example)
[Other jurisdiction][Law, decree or regulation, with article][Threshold][Deadline, language][Yes / No, reason]

1.3 Scope and conventions

ItemConvention
Entities coveredAll constituent entities in the consolidation scope, including permanent establishments
PeriodFinancial year [YYYY]; facts as at the year end unless stated
Currency[EUR]; local amounts translated at the average rate for income items and closing rate for balances
Source of financial data[Audited consolidated financial statements / group reporting packages]
Materiality[Transactions above EUR [x]k per year, or all transactions of a category] Example: EUR 1,000k per counterparty pair and category
Language[English]; translations prepared for [jurisdictions]

Explain any deviation from these conventions where it occurs, and use the same conventions in the local files and the CbC report. A master file that uses statutory accounts while the CbC report uses consolidation packages creates differences that tax auditors will query.

2. Organisational structure

2.1 Legal and ownership chart

Show every constituent entity with its legal form, country and ownership percentage. For larger groups, show the operating structure in one chart and attach the complete legal chart as an appendix. Mark the ultimate parent entity and any surrogate parent used for the CbC report.

2.2 Entity list

Entity IDLegal nameJurisdictionOwnershipMain activityFTE at year end
OST-NL (Example)Ostrander Group N.V.NetherlandsUltimate parentGroup management, platform development control and ownership, brand, procurement, sales in the EU outside Germany1,400
OST-DE (Example)Ostrander Deutschland GmbHGermany100% by OST-NLSales, marketing and customer support for Germany, Austria and Switzerland600
OST-UK (Example)Ostrander UK LtdUnited Kingdom100% by OST-NLSales, marketing and customer support for the UK and Ireland450
OST-US (Example)Ostrander IncUnited States100% by OST-NLSales, marketing and customer support for North America650
OST-VN (Example)Ostrander Vietnam Co., LtdVietnam100% by OST-NLSoftware development services for OST-NL; small local resale of commerce products2,900
Total6,000

Use the entity IDs throughout the file, in the local files and in the CbC workpaper. Add a row for each permanent establishment and each dormant entity, because the CbC report lists them too.

2.3 Changes during the year

Change IDDateChangeEffect on transfer pricing
CHG-001 (Example)2026-04-0140 engineering roles relocated from OST-NL to OST-VNVietnam cost base and service fee increase; no transfer of intangibles because OST-NL keeps control of development
[CHG-NNN]YYYY-MM-DD[Acquisition, merger, liquidation, new branch][Effect]

3. Description of the business

3.1 Important drivers of business profit

Describe in plain words the few factors that explain most of the group's profit, and say which entity controls each one.

Driver IDProfit driverControlled byEvidence
DRV-001 (Example)Platform functionality and reliability, which drive merchant retentionOST-NL product and engineering leadershipProduct roadmap, net revenue retention reports
DRV-002 (Example)Brand recognition among small and mid-sized merchantsOST-NL marketing strategy; local execution by OST-DE, OST-UK and OST-USBrand guidelines, marketing budget approvals
DRV-003 (Example)Scale purchasing of point-of-sale hardwareOST-NL procurementSupplier contracts signed by OST-NL
DRV-004 (Example)Cost-efficient software development capacityOST-NL directs; OST-VN executesStatements of work, sprint plans approved in the Netherlands

3.2 Supply chains for the main products and services

Cover the group's five largest products or services by turnover and any other product or service line above [5]% of group turnover. A short flow diagram per product line is usually clearer than prose.

Product lineFY2026 revenue (EUR thousand)ShareMain marketsSupply chain summary
Subscription (Example)504,00056.0%EU, UK, USPlatform owned by OST-NL; local subscriptions resold by OST-DE, OST-UK and OST-US
Commerce (Example)315,00035.0%EU, UK, US, VietnamHardware bought by OST-NL from third parties, resold to the distributors
Services (Example)81,0009.0%EU, UK, USDelivered by the selling entity with remote support from OST-NL
Total900,000100.0%

Check: 504,000 + 315,000 + 81,000 = 900,000; shares 56.0% + 35.0% + 9.0% = 100.0%.

3.3 Main service arrangements between group entities

Arrangement IDServiceProviderRecipientsPricing basis
SVC-001 (Example)Contract software developmentOST-VNOST-NLTotal operating costs plus 8% (TPP-002)
SVC-002 (Example)Finance, HR, IT and legal supportOST-NLOST-DE, OST-UK, OST-US, OST-VNAllocated cost plus 5% under a low value-adding services approach, allocated by a weighted key of external revenue and system users (TPP-003)
[SVC-NNN][Service][Entity][Entities][Basis]

Describe the capabilities of the main service providers (for example the Vietnamese engineering centre: headcount, skills, management line) and the allocation keys used for shared costs (headcount, revenue, users). Example: The FY2026 SVC-002 charge of EUR 13,000k (OST-DE 4,000, OST-UK 3,000, OST-US 4,500, OST-VN 1,500) is allocated by a key that weights external revenue and system users equally. A pure headcount key was rejected: OST-VN has 2,900 of the 4,600 subsidiary employees (63%) but uses few of the finance, legal and commercial support services, so a headcount key would charge it for services it does not benefit from.

3.4 Main geographic markets

MarketSelling entityFY2026 external revenue (EUR thousand)
Netherlands and other EU outside DACH (Example)OST-NL300,000
Germany, Austria, Switzerland (Example)OST-DE210,000
UK and Ireland (Example)OST-UK150,000
North America (Example)OST-US225,000
Vietnam (Example)OST-VN15,000
Total900,000

3.5 Functional analysis summary

Summarise the main contributions to value creation by each entity. The local files contain the detailed analysis; this table is the group view that all local files must be consistent with. Use "L" for lead (performs and controls), "S" for supports (performs under direction) and a blank cell for no involvement.

Function, asset or riskOST-NLOST-DEOST-UKOST-USOST-VN
Strategic managementL
Product and platform development (control)L
Software development (execution)SL
Brand and marketing strategyLSSS
Local sales and customer supportL (EU)L (DACH)L (UK)L (US)L (VN resale)
Procurement of hardwareL
Inventory riskLS (limited)S (limited)S (limited)S (limited)
Market riskLS (limited)S (limited)S (limited)
Credit risk on customersL (EU)L (DACH)L (UK)L (US)L (VN)
Development risk (failure of projects)L
Ownership of platform and brandL
Working capital fundingLSSSS

Example: OST-DE, OST-UK and OST-US carry limited market and inventory risk because OST-NL sets prices, approves stock levels and accepts returns of obsolete stock. Their remuneration therefore targets a stable operating margin (TPP-001). OST-VN performs development under detailed statements of work issued and approved in the Netherlands; it does not decide which projects to fund and does not bear development failure risk, which supports a cost-plus return (TPP-002).

Read the functional table together with the profit drivers in 3.1. The entity that leads the drivers which explain most of the profit should earn the residual return; entities that support under direction should earn a routine, benchmarked return. If the table shows several entities leading the same valuable driver, consider whether a profit split is more appropriate than one-sided methods, and document why it was or was not selected.

3.6 Business restructurings, acquisitions and divestitures

List restructurings, acquisitions and disposals during the year, including any transfer of functions, assets or risks between entities. State how any compensation for the transfer was assessed, or why none was due.

Event IDDateDescriptionCompensation analysis
RST-001 (Example)2026-04-01Relocation of 40 engineering roles from the Netherlands to Vietnam (CHG-001)No transfer of intangibles or customer relationships; roles moved under the existing service agreement; no exit payment due
[RST-NNN]YYYY-MM-DD[Event][Analysis or reference to a separate memo]

4. Intangibles

4.1 Strategy for intangibles

Describe where research and development takes place, where it is managed and who decides on funding, priorities and protection. Explain the role of each entity in the DEMPE functions (development, enhancement, maintenance, protection and exploitation).

Example: The platform roadmap is set by the product leadership team in the Netherlands, which approves budgets and accepts or rejects each release. Development work is carried out about 65% in Vietnam and 35% in the Netherlands. Patents and trademarks are registered in the name of OST-NL, which funds all development and bears the risk that a project fails. Local distributors contribute market feedback but do not direct development.

Test this description against the people who actually take decisions. If the engineering director who approves releases is employed by the Vietnamese company, or if the UK sales team negotiates platform features with large customers and commits development resources, the control analysis changes and the pricing in section 7 may no longer fit. Interview the people, read board and product committee minutes, and record the evidence in the local files.

4.2 List of important intangibles

Intangible IDIntangibleLegal ownerDEMPE controlUsed by
INT-001 (Example)Ostrander platform source code and know-howOST-NLOST-NLAll entities, through resale or service delivery
INT-002 (Example)Ostrander trademarks and domain namesOST-NLOST-NLAll entities
INT-003 (Example)Customer lists and merchant dataSelling entitySelling entity under group policiesSelling entity
[INT-NNN][Intangible][Entity][Entity][Entities]

4.3 Agreements on intangibles and main services

Agreement IDTypePartiesEffective dateKey terms
AGR-001 (Example)Contract research and development services agreementOST-VN to OST-NL2022-01-01All results vest in OST-NL; cost plus 8%; quarterly invoicing
AGR-002 (Example)Distribution agreements (one per distributor)OST-NL with OST-DE, OST-UK and OST-US2021-07-01Non-exclusive right to resell; trademark use included in the purchase price; year-end margin true-up
AGR-003 (Example)Supply agreement for resale of hardwareOST-NL with OST-VN2023-03-01Price set for a target operating margin of the reseller; obsolete stock returned to OST-NL
AGR-004 (Example)Group services agreementOST-NL with all subsidiaries2021-07-01Allocated cost plus 5%, allocated by a weighted key of external revenue and system users; no charge for shareholder activities
[AGR-NNN][Licence, cost contribution arrangement, service agreement][Parties]YYYY-MM-DD[Terms]

4.4 Transfer pricing policies for research and intangibles

Explain how development activity and the use of intangibles are remunerated. Example: OST-VN receives cost plus 8% for development services (TPP-002). The value of the platform and brand is captured by OST-NL as residual profit, because the distributors earn a routine margin (TPP-001) that already includes the right to use the trademarks in their resale activity. No separate royalty is charged.

4.5 Transfers of intangibles during the year

List any transfer of interests in intangibles between group entities, with the entities, countries and compensation. Example: None in FY2026.

5. Intercompany financial activities

5.1 Financing of the group

ItemDescription
External financing (Example)Term loan of EUR 100,000k and revolving credit facility of EUR 150,000k with a bank syndicate, borrower OST-NL
Central financing functionOST-NL group treasury manages liquidity, foreign exchange and funding
Central financing entity (Example)OST-NL, organised in the Netherlands, place of effective management [city], Netherlands
Cash pooling (Example)Zero-balancing EUR cash pool with OST-NL as pool leader; OST-DE, OST-UK and OST-US participate through EUR sub-accounts

5.2 Intercompany financial transactions

Transaction IDTypeLender or providerBorrower or recipientAmount (EUR thousand)Pricing
FIN-001 (Example)Term loan, 5 years, fixed rateOST-NLOST-US60,0005.2% fixed, based on a stand-alone credit rating of OST-US and market yields (TPP-004); interest FY2026 EUR 3,120k
FIN-002 (Example)Cash pool balancesOST-NL (leader)OST-DE, OST-UK, OST-USDaily balances, peak 40,000Reference rate plus or minus a spread; leader earns a service return (TPP-005)
[FIN-NNN][Guarantee, hedging, captive insurance][Entity][Entity][Amount][Basis]

Check: 60,000 x 5.2% = 3,120 for a full year.

5.3 Financing policy

Describe the policy used to price intercompany financing: credit rating method, reference rates, the treatment of implicit group support, guarantee fees, and cash pool remuneration. The financial transactions guidance is in Chapter X of the OECD Guidelines (2022 edition).

Example: OST-NL lends to OST-US because the US company needed funding for working capital when it opened two regional sales offices. Treasury first estimated a stand-alone credit rating for OST-US from its own financial ratios, then considered whether the parent would support it in distress, and finally selected market yields for five-year debt of borrowers with a similar rating, currency and term. The resulting fixed rate of 5.2% sits inside the range of those yields. OST-NL charges no guarantee fees in FY2026 because no group entity guarantees third-party debt of another.

Write this section so that a reader understands three things: which entity bears the group's financing risk, whether any entity is funded mainly by intercompany debt rather than equity, and whether interest deductions in any country could be restricted by local interest limitation rules.

6. Financial and tax positions

6.1 Consolidated financial statements

Attach or link the audited consolidated financial statements for the year, or the financial statements prepared for regulatory or internal management purposes if no audited set exists.

ItemFY2026 (EUR thousand)
Revenue (Example)900,000
EBITDA (management measure) (Example)135,000
Depreciation and amortisation (Example)(40,000)
Operating profit (Example)95,000
Net finance cost (Example)(5,000)
Profit before tax (Example)90,000
Income tax expense (current 23,400, deferred 600) (Example)(24,000)
Profit for the year (Example)66,000

Check: 135,000 - 40,000 = 95,000; 95,000 - 5,000 = 90,000; 90,000 - 24,000 = 66,000; EBITDA margin 135,000 / 900,000 = 15.0%.

6.2 Advance pricing agreements and rulings

Ruling IDTypeJurisdictionsCovered transactionsTermStatus
APA-001 (Example)None in force in FY2026Not applicable
[APA-NNN][Unilateral APA / bilateral APA / ruling][Countries][Transactions][Years][In force / In negotiation]

6.3 Open audits and mutual agreement procedures

List open transfer pricing audits, adjustments proposed and mutual agreement procedure cases, so that every local file reports the same facts. Example: A German tax audit of OST-DE for FY2022 to FY2024 was open at 2026-12-31; no adjustment had been proposed.

Keep this section factual and short. Do not argue the merits of an open case in the master file; refer to the local file of the entity concerned, and make sure the description does not contradict submissions already made to the tax authority. Where a past audit led to an adjustment, state whether the group changed its policy as a result, because a recurring adjustment on the same transaction suggests that the policy itself needs review.

7. Transfer pricing policy summary

Policy IDTransaction typeMethodTested partyIndicator and targetMonitoring and true-up
TPP-001 (Example)Purchase and resale of subscriptions and goods by distributorsTransactional net margin method (TNMM)OST-DE, OST-UK, OST-USOperating margin (operating profit / net sales) target 3.0%, within the benchmarked rangeQuarterly margin review; year-end adjustment invoice before books close
TPP-002 (Example)Contract software developmentTNMMOST-VNNet cost plus (operating profit / total operating costs) target 8.0%Monthly invoicing at budget cost plus 8%; true-up to actual costs in December
TPP-003 (Example)Group support servicesCost plus, low value-adding services simplified approach (OECD Chapter VII, section D)OST-NL as providerAllocated cost plus 5%Annual allocation by a weighted key (50% external revenue, 50% system users), reviewed for the benefit test
TPP-004 (Example)Intercompany term loansComparable uncontrolled price using market yields for the borrower's stand-alone ratingOST-US as borrowerFixed rate set at drawdownRating reviewed annually; rate fixed for the term
TPP-005 (Example)Cash poolComparable uncontrolled price for deposit and borrowing rates; service return for the leaderOST-NL as leaderReference rate plus or minus spreadMonthly interest allocation

Describe how the policies are implemented in invoicing and accounting (intercompany agreements, systems, true-up timing) and who in finance owns each policy. A short statement of the year-end result per policy helps tax auditors: Example: OST-DE, OST-UK and OST-US each 3.0% operating margin after true-up; OST-VN net cost plus 8.0% on the development segment.

Note on drafts: the OECD opened a public consultation on a revision of Chapter VII (intra-group services) in 2026. It is a draft and does not replace the 2022 text. Check the status before the next annual update. Where a jurisdiction has adopted the OECD simplified and streamlined approach for baseline distribution activities (Amount B, added as an annex to Chapter IV in 2024), check whether the commerce segment of the distributors is eligible; the subscription resale (software services) is generally outside its scope, so test it under TPP-001.

8. Cross-reference to OECD Annex I and local rules

ItemOECD Annex I headingSection in this fileGermany (GAufzV master file annex)Vietnam (Decree 255/2026/ND-CP)UK (SI 2023/818)
MF-01Organisational structure2.1, 2.2CoveredCoveredCovered
MF-02Business description: profit drivers3.1CoveredCoveredCovered
MF-03Supply chains for main products3.2CoveredCoveredCovered
MF-04Main service arrangements3.3CoveredCoveredCovered
MF-05Main geographic markets3.4CoveredCoveredCovered
MF-06Functional analysis summary3.5CoveredCoveredCovered
MF-07Restructurings, acquisitions, divestitures3.6CoveredCoveredCovered
MF-08Intangibles strategy4.1CoveredCoveredCovered
MF-09List of intangibles and owners4.2CoveredCoveredCovered
MF-10Agreements on intangibles4.3CoveredCoveredCovered
MF-11Pricing policies for research and intangibles4.4CoveredCoveredCovered
MF-12Transfers of intangibles4.5CoveredCoveredCovered
MF-13Group financing5.1, 5.2CoveredCoveredCovered
MF-14Financing policy5.3CoveredCoveredCovered
MF-15Consolidated financial statements6.1CoveredCoveredCovered
MF-16APAs and rulings6.2CoveredCoveredCovered
MF-17Local add-on: transaction matrixLocal file DERequired for each entity (section 90(3) AO)Not applicableNot applicable
MF-18Local add-on: language and translation9.2German on request (check)Vietnamese translation on request (check)English
[MF-NN][Other local item][Section]

"Covered" means the section answers the item at the level the local rule expects in the reviewer's judgement. Mark gaps as "Gap" and assign an owner in section 9.

9. Preparation, review and maintenance

9.1 Annual calendar

StepOwnerDue (example for calendar year groups)
Data request to entity finance leads and business owners[@tp-manager]Year end plus 1 month
Functional interviews (product, engineering, sales, treasury)[@tp-manager]Year end plus 2 months
Draft master file[@tp-manager]Year end plus 4 months
Reconciliation to CbC report and consolidated accounts[@group-controller]Year end plus 5 months
Approval by Head of Tax and CFO[@head-of-tax], [@cfo]Before the earliest local tax return deadline
Translation and local distribution[@local-finance-leads]As local law requires

9.2 Quality checks before approval

  1. Every entity in the CbC report appears in section 2, with the same name and jurisdiction.
  2. Every policy in section 7 has a matching agreement in section 4.3 or 3.3 and appears in each relevant local file.
  3. The functional analysis in section 3.5 matches the local file analyses; a distributor described as limited-risk here cannot bear full inventory risk in its local file.
  4. Financial figures reconcile to the consolidated statements in 6.1.
  5. Restructurings in 3.6 match the changes in the legal chart in 2.3.
  6. Drafts and proposals (such as the 2026 Chapter VII consultation) are not cited as current rules.

9.3 Retention and distribution log

DateRecipientVersionPurposeSent by
YYYY-MM-DD[Tax authority, office][1.0][Audit request reference][@name]

Keep the file and its supporting evidence for at least the longest statutory retention period among the group's jurisdictions; check local law.

10. Glossary and references

10.1 Glossary

TermMeaning
Arm's length principlePricing between associated enterprises as independent enterprises would price comparable transactions in comparable circumstances
APAAdvance pricing agreement between a taxpayer and one or more tax authorities
DEMPEDevelopment, enhancement, maintenance, protection and exploitation of intangibles
Limited-risk distributorA distributor that buys and resells but does not control market, inventory or development risk
Master fileGroup-level transfer pricing document under OECD Chapter V, Annex I
Local fileEntity-level transfer pricing document under OECD Chapter V, Annex II
MNE groupMultinational enterprise group: entities under common control in more than one jurisdiction
TNMMTransactional net margin method: compares a net profit indicator of the tested party with those of comparable independent companies
Tested partyThe party to a transaction whose profit indicator is tested, usually the less complex one
UPEUltimate parent entity

10.2 References

ReferenceVersion or date checkedUse
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations2022 edition (January 2022), checked 2026-10-25Chapter V and Annex I structure; Chapter VII section D; Chapter X; Amount B annex to Chapter IV (2024)
UK Transfer Pricing Records Regulations 2023 (SI 2023/818)As made, for periods from 2023-04-01Jurisdiction row
US Treas. Reg. 1.6662-6(d)(2)(iii)eCFR text checked 2026-10-25Principal documents and 30-day rule
Vietnam Decree 255/2026/ND-CP (transfer pricing, related-party transactions)Effective 2026-07-01Jurisdiction row; confirm deadlines in the decree text
Germany Section 90(3) and (4) AO; GAufzVText checked 2026-10-25Master file threshold, transaction matrix, 30-day rule
OECD Pillar Two side-by-side packageJanuary 2026Context for CbC data reuse, by reference
[Group transfer pricing policy manual][Version]Internal implementation

Standard and licence note

Structure aligned with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, Chapter V, Annex I (OECD, used for structure and references only under the OECD terms and conditions; OECD material published from 2024-07-01 is available under CC BY 4.0). This is an adaptation in original wording; it does not represent the official views of the OECD or its Member countries. The jurisdiction rows are based on public law: UK SI 2023/818 (Open Government Licence v3.0), US Treas. Reg. 1.6662-6 (US public domain), Vietnam Decree 255/2026/ND-CP and German section 90 AO with the GAufzV, all paraphrased in original words. Ostrander Group N.V., its subsidiaries and every figure are fictional. This template is original text written for this collection. Check the current official versions of the guidelines and each local law before use. Template licence: MIT.

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