How Can You Master the Master File?

While all aspects of the OECD Guidelines on the three pronged approach to global documentation are important, a well-prepared Master File sets the tone for the other documents.

The Master File is a singular descriptive report prepared for an entire multinational enterprise group that provides a high-level overview of the company's global business operations and places the group's transfer pricing practices in its global economic, legal, financial, and tax context. 

As of the publication of this episode:

• Over 50 countries have implemented a Master File for years 2016 through 2021, and over 90 percent of those countries with requirements have penalties associated with Master File.

Our host Brittany Hardin Tanguay discusses more about the Master File with Kristin Essary, a Principal in the KPMG Transfer Pricing practice, and Steve Blough, a retired KPMG Tax Principal.

About our guest: Steve Blough joined KPMG in 1994. In his 27 years with the firm, he held a variety of leadership positions and was involved in many transformative changes, and was a leader in intellectual property issues in transfer pricing. A prodigious writer and speaker, he has presented extensively on topics such as the reconciliation of transfer pricing and financial statement valuation approaches to IP valuation. He led KPMG global efforts with respect to tracking, commenting, speaking, and advising clients on the evolution of transfer pricing rules through the OECD’s BEPS projects, and numerous other firm initiatives during his career.