CTBD CPA Limited
A registered firm of AFRC


Master file & Local file

Master File

The master file provides a high-level overview of the global operations and policies of a group, including the global business operations, transfer pricing policies and global allocation of income and economic activities.  The master file provides an overall blueprint of the various business lines of a group.

We are pleased to assist our client to prepare the master by including the following major information:

  • Organizational structure of the group;
  • Descriptions of the business of the group;
  • Intangible of the group;
  • Intercompany financial activities of the group; and
  • Financial and tax positions of the group.


Local File

The local file provides detailed transactional transfer pricing information specific to an entity in each jurisdiction. The local file supplements the master file and helps to demonstrate that the entity has complied with the arm’s length principle in its material transfer pricing transaction. The focus of the local file is on the transfer pricing analysis of the material transactions between the entity and its associated entities in different jurisdictions.

The local file will contain the sections as follows:

  • Industry analysis;
  • Company analysis;
  • Functional analysis;
  • Selection of transfer pricing methods;
  • Conclusions; and
  • Supporting appendices