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

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

Approvals

Revision history

Contents

• 1. Purpose, scope and legal basis
• 2. Organisational structure
• 3. Description of the business
• 4. Intangibles
• 5. Intercompany financial activities
• 6. Financial and tax positions
• 7. Transfer pricing policy summary
• 8. Cross-reference to OECD Annex I and local rules
• 9. Preparation, review and maintenance
• 10. Glossary and references
• Standard and licence note

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.

1.3 Scope and conventions

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

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

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.

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.

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

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

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.

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.

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

4.3 Agreements on intangibles and main services

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

5.2 Intercompany financial transactions

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.

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

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

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

"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

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

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

10.2 References

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.