Build the Action 13 file stack
Distinguish the master file, local file, and CbCR roles in transfer-pricing documentation.
Action 13 is a documentation stack, not three disconnected filings. Master file The master file answers, "How does the group create value globally?" It covers the group structure, main business lines, intangibles, financing, and transfer-pricing policies. Local file The local file answers, "Why is this jurisdiction's controlled transaction arm's length?" It needs transaction detail, functional analysis, method selection, financials, and comparables. CbCR The country-by-country report answers, "Where are profit, tax, people, assets, and activities located?" It is used for high-level risk assessment, so mismatches are invitations for follow-up. The useful habit is to build a consistency page before filing. If…
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