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Masterfile ensures consistency but doubts linger

February 17, 2010

Professionals harbour fears over inconsistent implementation across Europe and some go so far as to question whether the system change was necessary.

The idea of keeping a masterfile of transfer pricing documentation was introduced to help cut complexity in transfer pricing documentation throughout Europe. Today advisers think it has helped many taxpayers and tax authorities be more consistent in their documentation expectations, but concerns over implementation remain.

The masterfile, which is endorsed by the European Council and the EU Joint Transfer Pricing Forum, is one single set of standardised documentation that serve as the basis for preparing specific local country documentation.

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