OECD master file and local file requirements by country (2026)
What 75 countries require: thresholds, deadlines and local forms, read from each country's own tax authority.
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Transfer pricing coverage
Verified documentation rules for 75 countries. The darker a country, the more of the three OECD documents it asks for.
Last verified 19 October 2026
COUNTRY PAGES
Every country we cover
Each country has its own page with the thresholds, deadlines, local forms, penalties and the official sources behind them. 72 countries are written so far.
North America
Latin America & Caribbean
Europe
Middle East
Africa
Asia-Pacific
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ALL COUNTRIES
Master file and local file requirements, country by country
Every threshold and deadline for all 75 countries. "Above threshold" means the document applies only once you pass the limit below it, "filed or kept" is whether you hand it in or hold it until asked, and "not confirmed" means no official source states it yet.
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| Country | Master file threshold | Local file threshold | Filed or kept | Key deadline | CbC report threshold | Language | Local forms |
|---|---|---|---|---|---|---|---|
| ArgentinaLatin America & Caribbean | Above thresholdGroup consolidated annual revenue above ARS 100,000,000,000 in the prior year and cross-border related-party transactions above ARS 150,000,000 in total or ARS 15,000,000 individually | Above thresholdTransfer pricing study required where related-party transactions exceed ARS 150,000,000 in total or ARS 15,000,000 individually | Filed separately | Transfer pricing study (local file) and F. 2668: By the sixth month after fiscal year close, per CUIT schedule | RequiredEUR 750,000,000 consolidated group revenue (or equivalent in the ultimate parent's currency at the January 2015 exchange rate) | Spanish; foreign-language documents need a Spanish translation by a sworn public translator | Form F. 2668 (transfer pricing informative return); Form F. 2673 (master file filing); Forms F. 8096 (notification) and F. 8097 (country-by-country report) |
| AustraliaAsia-Pacific | Above thresholdCBC reporting entities: a CBC reporting parent, or member of its group, with annual global income of AUD 1 billion or more | Above thresholdCBC reporting entities (annual global income of AUD 1 billion or more) | Filed separately | CBC statements (CbC report, master file, local file): Within 12 months after the end of the reporting period | RequiredAnnual global income of AUD 1 billion or more | Penalty-protection records must be in English, or readily accessible and convertible into English | International Dealings Schedule (IDS); Public CBC report |
| AustriaEurope | Above thresholdEntity revenue above EUR 50 million in each of the two preceding fiscal years | Above thresholdEntity revenue above EUR 50 million in each of the two preceding fiscal years | Kept, filed on request | Master file and local file: Within 30 days of request | RequiredEUR 750 million total group revenue in the preceding fiscal year | An official language allowed in tax proceedings (German) or English | None |
| BelgiumEurope | Above thresholdBelgian entity of an MNE group exceeding one of: turnover above EUR 50 million, balance sheet total above EUR 1 billion, or more than 100 FTE | Above thresholdSame as master file; extra detail required for business units with intra-group transactions above EUR 1 million | Filed with the return | Local file: With the annual tax return | RequiredEUR 750 million consolidated group revenue | English, French, Dutch or German | None |
| Bosnia and HerzegovinaEurope | Above thresholdFBiH: consolidated group figure above EUR 750 million (or BAM equivalent); RS: no threshold stated; Brcko: not required | RequiredFBiH and RS: documentation must be held when filing the CIT return; Brcko: filed with the return | Kept, filed on request | TP documentation on request (FBiH): Within 45 days of request | RequiredFBiH: consolidated group revenue of at least EUR 750 million (or BAM equivalent) | FBiH: local file in an official BiH language; master file may be in English, translation on request | TP-902 (FBiH related-party summary); Form 1102 (Brcko District) |
| BrazilLatin America & Caribbean | Above thresholdTotal controlled transactions of BRL 15 million or more in the prior calendar year (before adjustments) | Above thresholdControlled transactions of BRL 15 million or more in the prior year: simplified local file below BRL 500 million, full local file at BRL 500 million or more | Filed separately | Master file and local file: Within three months after the ECF deadline (last business day of July of the following year) | Required | A master file in a foreign language needs a Portuguese translation; English or Spanish files are translated only if the authority asks | Commodity controlled transactions reporting |
| CanadaNorth America | Not required | Above thresholdSection 247(4) contemporaneous records are needed to show reasonable efforts and avoid the 247(3) penalty. Simplified documentation under 247(4.1) applies where conditions prescribed by regulation are met. | Kept, filed on request | Section 247 contemporaneous documentation: By the documentation-due date (filing-due date); provide within 30 days of a written CRA request | RequiredEUR 750 million or more total consolidated group revenue in the immediately preceding fiscal year | Not confirmed | Form T106 (information return of non-arm's length transactions with non-residents); Form RC4649 (country-by-country report) |
| ChileLatin America & Caribbean | Above thresholdChilean-resident parent of an MNE group with consolidated revenue of at least EUR 750,000,000, or a Chilean group entity designated to file the CbC report (Form 1950) | Above thresholdAll three as of 31 December: in the Grandes Empresas segment; parent required to file a CbC report; related-party transactions with non-residents above CLP 200,000,000 in the year (Form 1951) | Filed separately | Forms 1907, 1937, 1950 and 1951: 30 June for the prior commercial year; filing between 1 July and 30 September counts as a request for a 3-month extension | RequiredGroup revenue of at least EUR 750 million in the 12 months before the tax period (Chilean-resident parent; Form 1937) | Master file and local file in Spanish or English; SII may ask for a Spanish translation in specific cases | Form 1907 (annual transfer pricing sworn statement); Form 1937 (country-by-country report); Form 1950 (master file) and Form 1951 (local file) |
| ChinaAsia-Pacific | Above thresholdCross-border related-party transactions in the year and the group's ultimate controlling company has prepared a master file, or annual related-party transactions exceed RMB 1 billion | Above thresholdAny of: tangible asset transfers above RMB 200 million; financial asset transfers above RMB 100 million; intangible asset transfers above RMB 100 million; other related-party transactions above RMB 40 million in total. APA-covered amounts excluded; domestic-only groups exempt. | Kept, filed on request | Local file and special file: By 30 June of the following year | RequiredGroup consolidated revenue above RMB 5.5 billion in the prior year (China-resident ultimate controlling company, or designated reporting entity) | Chinese, citing the sources of information used | Annual Related-Party Transactions Report Forms (2016 edition); Special file (cost sharing agreements; thin capitalisation) |
| ColombiaLatin America & Caribbean | Above thresholdTaxpayers meeting the local file thresholds that belong to a multinational group (two or more companies tax resident in different jurisdictions) | Above thresholdGross equity of 100,000 UVT or more, or gross income of 61,000 UVT or more, with related-party transactions abroad or in free trade zones; not required for a transaction type at or below 45,000 UVT per year; 10,000 UVT for transactions with non-cooperative or preferential regimes | Filed separately | Local file and master file: September, 7th to 16th business day by last NIT digit | RequiredConsolidated accounting revenue of 81,000,000 UVT or more in the prior year | Local file in Spanish (foreign comparables data may be in English); master file may be in English; DIAN can request an official translation within 20 business days | Form 120 (transfer pricing informative return) |
| Costa RicaLatin America & Caribbean | RequiredNo threshold or exemption applies | RequiredNo threshold or exemption applies | Kept, filed on request | Local file: Within 10 business days of a request during an audit | Required | Spanish for the master file and local file; no language limit stated for the CbC report | Declaración Informativa en materia de Precios de Transferencia (filed in TRIBU-CR) |
| Côte d'IvoireAfrica | Above thresholdCompanies under the Large or Medium Enterprises directorates that control or are controlled by foreign entities, with annual turnover (VAT included) above XOF 500 million | Above thresholdSame as master file: Large or Medium Enterprises directorate companies linked to foreign entities with turnover (VAT included) above XOF 500 million | Kept, filed on request | Master file and local file: On request; fine applies if still missing 30 days after formal notice | RequiredIvorian parent with consolidated revenue excluding VAT of XOF 250 billion or more in the prior year (reduced from XOF 491,967,750,000 by art. 14 of the 2024 finance law annex) | Not confirmed | Intragroup international transactions statement (ETII, CGI art. 36) |
| CroatiaEurope | RequiredNo threshold stated | RequiredNo threshold stated | Kept, filed on request | PD-IPO related-party form: With the profit tax return | RequiredEUR 750 million total consolidated group revenue | Croatian as a rule; English accepted, with a Croatian translation where required | PD-IPO (related-party transactions form) |
| Czech RepublicEurope | Not requiredNot required by law; recommended by Ministry of Finance Guidance D-334 | Not requiredNot required by law; country-specific documentation recommended by Guidance D-334 | Kept, filed on request | Related-party transactions overview (annex): With the corporate income tax return | RequiredEUR 750 million consolidated group revenue | Not confirmed | Overview of transactions with related parties (annex to the corporate income tax return, MFin 5404) |
| DenmarkEurope | Above thresholdRequired for entities under section 38 Tax Control Act; groups with fewer than 250 employees and either balance sheet under DKK 195 million or revenue under DKK 391 million document only transactions with non-EU/EEA non-treaty counterparties; from income year 2025 companies with cross-border controlled transactions under DKK 5 million in total are out of scope | Above thresholdSame scope and exemptions as the master file | Filed separately | Master file and local file (filed): Within 60 days of the tax return filing deadline | RequiredDKK 5.6 billion consolidated group turnover per income year | Danish, Norwegian, Swedish or English | Controlled transactions disclosure in the corporate tax return (fields 503, 505a, 542, 542a); form 05.022 for hydrocarbon-tax companies |
| Dominican RepublicLatin America & Caribbean | Above thresholdMembers of multinational groups meeting Regulation 78-14 art. 2(1); same exemptions as the local report | Above thresholdExempt if related-party transactions total DOP 16,025,436.00 or less in the year and there are no transactions with tax-haven or preferential-regime residents; transactions with resident related parties are exempt; amount indexed yearly | Filed separately | DIOR: 120 days after fiscal year end (with the IR-2 return) | RequiredConsolidated group revenue of DOP 38,800,000,000.00 or more | Spanish | DIOR (Declaración Informativa de Operaciones entre Relacionados) |
| EcuadorLatin America & Caribbean | Not confirmed | Above thresholdInforme Integral de Precios de Transferencia (IIPT) where related-party transactions exceed USD 10,000,000 in the fiscal year | Filed separately | AOPR: Within two months after the income tax return due date | Not confirmed | Not confirmed | Anexo de Operaciones con Partes Relacionadas (AOPR); Informe Integral de Precios de Transferencia (IIPT) |
| El SalvadorLatin America & Caribbean | Not confirmed | Above thresholdTaxpayers that must file the F-982 need a TP study and supporting records under Guide DG-002/2018 | Not confirmed | F-982 related-party report: Within three months after fiscal year end | Not confirmed | Not confirmed | F-982 Informe de Operaciones con Sujetos Relacionados |
| EstoniaEurope | Above thresholdSame population as the local file: credit institutions, insurers and listed issuers; parties to transactions with non-cooperative jurisdictions; and entities with 250+ staff, EUR 50 million+ turnover or EUR 43 million+ balance sheet (counting associates) | Above thresholdCredit institutions, insurers and listed issuers; parties to transactions with non-cooperative jurisdictions; and entities (incl. PEs) with 250+ staff, EUR 50 million+ turnover or EUR 43 million+ balance sheet (counting associates) | Kept, filed on request | Master file / local file: On request, within at least 60 days | RequiredEUR 750 million consolidated group revenue | Foreign-language documents accepted; EMTA may ask for an Estonian translation within a reasonable time | None |
| FinlandEurope | Above thresholdCompanies that are not SMEs: 250 or more employees, or turnover above EUR 50 million and balance sheet above EUR 43 million (group figures count). Not needed for counterparties with transactions of EUR 500,000 or less a year | Above thresholdSame size test; lighter content for counterparties with transactions of EUR 500,000 or less a year | Kept, filed on request | TP documentation (master and local file): Within 60 days of request, not earlier than 6 months after year end | RequiredEUR 750 million consolidated turnover | Finnish, Swedish or English; key parts of English documentation may need translation | Form 78 (Explanation of transfer prices) |
| FranceEurope | Above thresholdEntities with annual turnover (excl. VAT) or gross assets of at least EUR 150 million, entities owning or owned more than 50% by such an entity, and members of a tax group that includes one (fiscal years opened from 1 Jan 2024) | Above thresholdSame scope as the master file; covers transaction categories above EUR 100,000 a year | Kept, filed on request | Master file and local file: Available at start of tax audit; within 30 days of formal notice if missing | RequiredEUR 750 million group revenue | In principle French; the tax authority may ask for translation of documents in another language | Form 2257-SD (annual simplified TP return, Article 223 quinquies B CGI) |
| GermanyEurope | Above thresholdEntity revenue of EUR 100 million or more in the preceding fiscal year | Above thresholdRequired unless the entity is a smaller enterprise: related-party supplies of goods not above EUR 6 million and other related-party services not above EUR 600,000 in the financial year (both limits must be met; related domestic entities are combined). Smaller enterprises must still give information and supporting documents on request. | Kept, filed on request | Local file: Within 30 days of request | RequiredEUR 750 million consolidated revenue in the previous fiscal year (domestic group parent) | German; another language (English) if justified; a German translation can be requested or required in court proceedings. CbC reports accepted in English. | Transaction matrix (Transaktionsmatrix); CbCR disclosure in corporate tax return (Anlage WA, lines 27 to 29) |
| GhanaAfrica | Above thresholdContemporaneous documentation (master file and local file parts) for each year of assessment; arrangements up to the cedi equivalent of USD 200,000 are exempt (Reg 14(1)) | Above thresholdSame as master file: arrangements up to the cedi equivalent of USD 200,000 are exempt (Reg 14(1)) | Filed separately | TP documentation (electronic copy): Within four months after the end of the basis period | RequiredGroups with consolidated revenue below GHS 2.9 billion are excluded (Reg 17 definition of excluded group) | Not confirmed | Annual transfer pricing return (Reg 11); LVAS or technology transfer election notice (Reg 14(5), 14(9)) |
| GreeceEurope | Above thresholdSame exemptions as the local file | Above thresholdExempt if intra-group transactions do not exceed EUR 100,000 a year (turnover up to EUR 5 million) or EUR 200,000 a year (turnover above EUR 5 million) | Kept, filed on request | Master file / local file (prepared): By the income tax return deadline | Required | Greek; a master file in English is accepted for foreign groups, with a Greek translation within 30 days of request | Summary Information Table (TP summary filing) |
| HondurasLatin America & Caribbean | Not confirmed | Above thresholdTaxpayers with related-party transactions; not required where all related parties are domestic and none is under a special tax regime (Tax Code art. 113) | Kept, filed on request | Form 545 TP informative return: 30 April (calendar year); 3 months after year end (special periods) | RequiredEUR 750 million consolidated group revenue, in national currency equivalent | No general TP language rule; foreign-language documents can be translated by Honduran consulates or the Official Translator | Form 545, Declaración Jurada Informativa Anual sobre Precios de Transferencia |
| Hong KongAsia-Pacific | Above thresholdRequired unless exempt. Business-size exemption: meet any two of revenue not over HKD 400 million, total assets not over HKD 300 million, average employees not over 100 | Above thresholdBusiness-size exemption as for the master file, or per-category exemption where controlled transactions are below: property transfers HKD 220 million, financial assets HKD 110 million, intangibles HKD 110 million, other HKD 44 million. Specified domestic transactions are excluded. | Kept, filed on request | Master file and local file: Within 9 months after the end of the accounting period | RequiredHKD 6.8 billion consolidated group revenue in the preceding accounting period | English or Chinese | Profits tax return and Supplementary Form S2 (declaration on master file and local file) |
| HungaryEurope | Above thresholdEligible related-party transactions above HUF 500 million | Above thresholdNot required for transactions not exceeding HUF 150 million (arm's length value excl. VAT); unchanged cost recharges exempt up to HUF 500 million | Kept, filed on request | Local file and master file (prepared): By the corporate tax return filing | RequiredEUR 750 million consolidated revenue in the preceding financial year | Hungarian, English or German | TP data reporting in the CIT return (ATP-01 and ATP-KV sheets of forms 29, 29EUD, 71) |
| IcelandEurope | Not required | RequiredNo monetary threshold stated; minor transactions of limited scope are exempt (not intangibles) but must still be reported | Kept, filed on request | TP documentation (on request): Within 45 days of request | Required | Icelandic and/or English; CbC report in English on a set form | None |
| IndiaAsia-Pacific | Above thresholdFull Form 56 where consolidated group revenue exceeds INR 500 crore AND either international transactions exceed INR 50 crore OR intangible property transactions exceed INR 10 crore. Part A of Form 56 is due from every constituent entity of an international group even below these thresholds. | Above thresholdRequired where aggregate international transactions in the tax year exceed INR 1 crore, as recorded in the books | Kept, filed on request | Local documentation on request: Within 10 days of a notice; extendable by up to 30 days on application | RequiredINR 6,400 crore total consolidated group revenue | Not confirmed | Form 48 (accountant's report on international and specified domestic transactions, replaces Form 3CEB); Form 56 (master file; Part A for all constituent entities); Form 57 (designation of one constituent entity to file Form 56); Form 58 (CbC notification); Form 59 (CbC report); Form 60 (designated CbC filer) |
| IndonesiaAsia-Pacific | Above thresholdAny of: prior-year gross revenue above IDR 50 billion; prior-year related-party tangible goods transactions above IDR 20 billion; prior-year services, interest, intangibles or other related-party transactions above IDR 5 billion; or a related party in a jurisdiction with a lower income tax rate than Indonesia | Above thresholdSame tests as the master file (PMK-172 Article 16(3)) | Kept, filed on request | Master file and local file availability: Within 4 months after the end of the tax year | RequiredIndonesian parent with prior-year consolidated gross revenue of at least IDR 11 trillion (foreign parent test: EUR 750 million) | Indonesian; a foreign language only for taxpayers permitted to keep books in a foreign language, with an Indonesian translation | Summary (ikhtisar) of master file and local file |
| IrelandEurope | Above thresholdGroup consolidated turnover of EUR 250 million or more | Above thresholdGroup consolidated turnover of EUR 50 million or more | Kept, filed on request | Master file / local file: Prepared by the return filing date; provided within 30 days of a written request | RequiredEUR 750 million or more annual consolidated group revenue in the preceding fiscal year | Irish or English | None |
| IsraelMiddle East | Above thresholdIsraeli members of an MNE group with consolidated group revenue of NIS 150 million or more | RequiredMarket conditions (TP) study for international transactions between parties with a special relationship; no value threshold stated | Kept, filed on request | TP study (local file): Within 30 days of request | RequiredNIS 3.4 billion consolidated group revenue | Hebrew and/or English | Form 1385 (international transactions declaration) |
| ItalyEurope | Not requiredOptional; preparing it qualifies for penalty protection | Not requiredOptional (national documentation); preparing it qualifies for penalty protection | Kept, filed on request | Master file and national documentation (optional): Signed and time-stamped by the tax return filing date | RequiredEUR 750 million total consolidated group revenue (Italian ultimate parent) | Italian; the master file may be submitted in English | None |
| JapanAsia-Pacific | Above thresholdMNE group total consolidated revenue of JPY 100 billion or more in the preceding fiscal year | Above thresholdContemporaneous local file where, in the previous business year, transactions with one foreign related party total JPY 5 billion or more, or intangible transactions with it total JPY 300 million or more | Kept, filed on request | Local file (contemporaneous): Prepared by the final return filing deadline; presented by a date set by the examiner, up to 45 days after the request | RequiredMNE group total consolidated revenue of JPY 100 billion or more in the preceding fiscal year | CbC report in English. Master file in Japanese or English (a Japanese translation may be requested). No set language for the local file, but a Japanese translation may be requested. | Schedule 17(4) of the corporate tax return (details of foreign related parties) |
| JordanMiddle East | Above thresholdMembers of a multinational group (Art. 8(b)) | RequiredTaxpayers with related-party transactions; natural persons and small enterprises whose related-party transactions do not exceed JOD 500,000 in any 12 consecutive months are exempt from keeping TP documentation (Art. 16(b)) | Kept, filed on request | Related-party disclosure form: With the annual tax return | RequiredCombined group revenue above JOD 600,000,000 per the prior period's financial statements | Not confirmed | Related-party transactions disclosure form (Art. 9) |
| KenyaAfrica | RequiredNo size threshold stated in the October 2025 OECD profile | RequiredNo size threshold stated in the October 2025 OECD profile | Filed separately | Master file and local file: Within 6 months after the reporting financial year end | RequiredKES 95 billion annual group turnover | English or Kiswahili; other languages must be translated | None |
| LatviaEurope | Above thresholdControlled transactions above EUR 20,000,000 in the reporting year | Above thresholdControlled transactions above EUR 250,000 in the reporting year; transactions up to EUR 90,000 a year may be treated as not material | Kept, filed on request | Master file / local file (prepared): Within 12 months after year end | Required | Global documentation in Latvian or English; VID may ask for a Latvian translation within one month (2018 text) | Controlled transactions report (Kontroleto darijumu parskats), structured data via VID EDS |
| LithuaniaEurope | Above thresholdMembers of an international group (incl. foreign entities with a Lithuanian PE) with income above EUR 15 million in the preceding tax period | Above thresholdTurnover above EUR 3 million in the previous tax year (financial undertakings, credit institutions and insurers regardless of size); exempt if controlled transactions total under EUR 90,000 or are only with Lithuanian entities, subject to exceptions | Kept, filed on request | Master file / local file (prepared): By the 15th day of the sixth month of the following tax period | Required | Any language until requested; on request, provided in the original language and VMI may require a Lithuanian translation | TP return on controlled transactions; filed separately or annexed to the tax return. |
| LuxembourgEurope | Not required | Not requiredNo prescribed local file; TP documentation supporting taxable income must be provided on request (AO s.171(3)) | Kept, filed on request | Not confirmed | RequiredEUR 750 million group turnover | French or German; English also accepted | None |
| MalaysiaAsia-Pacific | Above thresholdNo separate master file: MNE group information forms Schedule 1 of a full contemporaneous TP documentation (CTPD), so full CTPD thresholds apply (see local_file) | Above thresholdFull CTPD where gross business income exceeds RM30 million and cross-border controlled transactions total RM10 million or more a year, or controlled financial assistance exceeds RM50 million a year. Others may prepare a full or minimum CTPD. No CTPD needed where total controlled transactions are RM1 million or less, and in some domestic-only cases. | Kept, filed on request | CTPD (full or minimum): Must exist before the due date for furnishing the return | RequiredConsolidated group revenue of at least RM3 billion (preceding financial year) | Not confirmed | None |
| MaldivesAsia-Pacific | Above thresholdPersons required to prepare TP documentation under Income Tax Act s.68; not required where associated-party transactions in the year total MVR 5 million or less (with listed exclusions) or the entity is a micro, small or medium enterprise under the SME Law (Reg. 7) | Above thresholdPersons required to prepare TP documentation under Income Tax Act s.68; not required where associated-party transactions in the year total MVR 5 million or less (with listed exclusions) or the entity is a micro, small or medium enterprise under the SME Law (Reg. 7) | Not confirmed | CbC notification: By the last day of the reporting fiscal year | RequiredMore than EUR 750 million consolidated group revenue in the preceding fiscal year | English or Dhivehi | None |
| MaltaEurope | Above thresholdCompanies in scope of the TP rules: cross-border arrangements with associated enterprises above the de minimis (aggregate arm's length value over EUR 6,000,000 for revenue items or EUR 20,000,000 for capital items in the preceding year); SMEs excluded | Above thresholdSame scope as the master file: cross-border arrangements above EUR 6,000,000 (revenue items) or EUR 20,000,000 (capital items); SMEs excluded | Kept, filed on request | Master file and local file: On MTCA request, within a reasonable time stated in the request | Required | English or Maltese | None |
| MexicoNorth America | Above thresholdTaxpayers listed in CFF art. 32-H fractions I to IV with related-party transactions, including those with prior-year revenue of at least MXN 1,062,919,860 (indexed annually; figure as given in the July 2025 OECD profile) | Above thresholdSame art. 76-A population as the master file. Separately, art. 76 IX supporting TP documentation applies to all taxpayers with related-party transactions except businesses with prior-year income up to MXN 13,000,000 and professional service providers up to MXN 3,000,000 (with exceptions). | Filed separately | Local file informative return (art. 76-A II): 15 May of the following year | RequiredMexican-resident controlling entity of an MNE group with prior-year consolidated accounting revenue of MXN 12,000 million or more | Local file in Spanish; master file may be filed in English (Miscellaneous rule 3.9.15) | Related-party transactions informative return (LISR art. 76 X; Annex 9 of the DIM); ISSIF (Informacion sobre Situacion Fiscal, CFF art. 32-H), including the related-party transactions section |
| NetherlandsEurope | Above thresholdGroup consolidated revenue of EUR 50,000,000 or more in the prior year | Above thresholdGroup consolidated revenue of EUR 50,000,000 or more in the prior year. Separately, art. 8b(3) requires all taxpayers (no threshold) to document intercompany transactions in free form. | Kept, filed on request | Master file / local file: In the records when the tax return is filed | RequiredGroup consolidated revenue of EUR 750,000,000 or more in the prior year | Dutch or English | None |
| New ZealandAsia-Pacific | Not requiredNo statutory master file. Inland Revenue expects documentation in line with OECD Guidelines Chapter V (Annexes I and II) and adds no requirements of its own | Not requiredNo statutory local file or threshold; taxpayers must keep records supporting their position and bear the burden of proof. Small businesses may use a questionnaire with explanatory notes | Kept, filed on request | CbC report: Within 12 months of the group's fiscal year end | RequiredNZ-headquartered groups with consolidated group revenue of EUR 750 million or more in the preceding income year (Inland Revenue cites about NZD 1.3 billion) | Not confirmed | International Questionnaire (annual, issued by Inland Revenue) |
| NorwayEurope | Above threshold | Above thresholdExempt if the company and associated enterprises have fewer than 250 employees in total and either sales income under NOK 400 million or balance sheet under NOK 350 million | Kept, filed on request | TP documentation (local file, master file): Within 45 days of request | RequiredConsolidated group revenue above NOK 6.5 billion | Norwegian, Swedish, Danish or English | Controlled transactions disclosure in the tax return (form RF-1123 up to income year 2022) |
| PakistanAsia-Pacific | Above thresholdConstituent entity of an MNE group with turnover above PKR 100 million (Rules 27K and 27L) | Above thresholdTransactions with associates exceeding PKR 50 million (Rules 27M and 27N) | Kept, filed on request | Master file and local file: Within 30 days of the Commissioner's request (extendable) | RequiredEUR 750 million or equivalent in PKR consolidated group revenue (Rule 27A(4)(g)) | Not confirmed | None |
| PanamaLatin America & Caribbean | Required | Required | Kept, filed on request | Local file (TP study): Within 45 business days of a request | RequiredEUR 750 million consolidated group revenue | Spanish | Form 930, Informe de Precios de Transferencia |
| ParaguayLatin America & Caribbean | Not confirmed | Above thresholdIRE taxpayers with prior-year gross income above PYG 10,000,000,000 and related-party transactions abroad (or domestic ones where a party is exempt or outside IRE); IRE taxpayers dealing with low or nil tax jurisdictions or free-zone or maquila users regardless of income, unless the presumed link is rebutted; SIMPLE and RESIMPLE taxpayers exempt | Filed separately | TP study (ETPT): July after a 31 December year end | Not confirmed | Not confirmed | Estudio Técnico de Precios de Transferencia (ETPT), PDF with spreadsheets via Marangatu; Comunicación de desvirtuación de la vinculación presuntiva con residentes del extranjero |
| PeruLatin America & Caribbean | Above thresholdGroup accrued income above 20,000 UIT and transactions within the TP rules of 400 UIT or more (Reporte Maestro, Form 3561) | Above thresholdAccrued income above 2,300 UIT; transactions of 100 UIT to under 400 UIT file Annex I only; 400 UIT or more file Annexes II to IV (Reporte Local, Form 3560) | Filed separately | Reporte Local (Form 3560): May-period schedule of the following year by RUC digit; FY2025 only: October 2026 period schedule | RequiredPrior-year consolidated group revenue of PEN 2,700,000,000 or more | Spanish for all informative returns and supporting information | Form Virtual 3560 (Reporte Local); Form Virtual 3561 (Reporte Maestro) |
| PhilippinesAsia-Pacific | Not confirmed | Above thresholdTP documentation mandatory for RPT Form filers with (a) gross sales above PHP 150 million and total related-party transactions above PHP 90 million, (b) related-party sales of tangible goods above PHP 60 million, or services, interest, intangibles or other transactions above PHP 15 million, or (c) TPD required in the prior period (RR 34-2020 s. 3) | Kept, filed on request | TP documentation: Within 30 calendar days of a BIR request; one 30-day extension | Not confirmed | Not confirmed | BIR Form 1709 (Related Party Transaction Form) |
| PolandEurope | Above thresholdEntity must prepare a local file, belongs to a group preparing consolidated statements, and group consolidated revenue exceeds PLN 200 million | Above thresholdPer homogeneous controlled transaction (net of VAT): above PLN 10 million for goods or financial transactions; above PLN 2 million for services or other transactions | Not confirmed | Local file: End of 10th month after fiscal year end | RequiredConsolidated revenue above PLN 3.25 billion (PLN reporting) or EUR 750 million (other cases) | Master file may be accepted in English; a Polish translation can be demanded within 30 days | TPR-C / TPR-P (transfer pricing information return) |
| PortugalEurope | Above thresholdNot required where total net sales and other income are below EUR 10 million | Above thresholdNot required where total net sales and other income are below EUR 10 million | Not confirmed | Master file and local file: 15th day of the 7th month after fiscal year end | RequiredEUR 750,000,000 consolidated revenue in the prior period | Portuguese; other languages may be accepted on request | TP return within the Annual Return of Simplified Corporate Information (IES) |
| QatarMiddle East | Above thresholdResident associated enterprises and Qatar PEs with annual turnover or total assets of QAR 50,000,000 or more, where at least one group entity is resident outside Qatar | Above thresholdAnnual turnover or total assets of QAR 50,000,000 or more, and at least one group entity resident outside Qatar | Filed separately | Master file and local file: By 30 June of the year following the reported fiscal year | RequiredQAR 3,000,000,000 combined group revenue in the preceding fiscal year | Not confirmed | Transfer Pricing Declaration |
| RomaniaEurope | Above thresholdNo standalone master file. Group information in line with OECD Annex I to Chapter V is part of the Romanian TP file, so it follows the TP file thresholds. | Above thresholdLarge taxpayers, per affiliated person and per category, annual values excl. VAT: services EUR 100,000; financing (interest) EUR 200,000; intangibles and royalties EUR 250,000; tangible assets EUR 350,000. Small and medium taxpayers: EUR 50,000; EUR 100,000; EUR 150,000; EUR 200,000. Below these, ANAF may still request a file on a risk basis. | Filed separately | TP file (large taxpayers): Within 30 working days after the annual CIT return deadline, via SPV | RequiredEUR 750 million consolidated group revenue in the prior fiscal year | Romanian. Documents in another language must come with a Romanian translation. | Annex 3 list of transactions per affiliated person (part of the TP file, in PDF and Excel) |
| Saudi ArabiaMiddle East | Above thresholdRequired unless the taxpayer's controlled transactions do not exceed SAR 6 million in a 12-month period (natural persons other than institutions also exempt) | Above thresholdRequired unless controlled transactions do not exceed SAR 6 million in a 12-month period | Kept, filed on request | Master file and local file: Within the period ZATCA sets, at least 30 days after request | RequiredConsolidated group revenue above SAR 3.2 billion in the preceding year | Not confirmed | Controlled Transactions Disclosure Form |
| SenegalAfrica | Required | Required | Filed with the return | Master file and local file: With the annual profit and loss return | RequiredConsolidated annual turnover excluding tax of XOF 491 billion or more in the preceding year | Not confirmed | None |
| SingaporeAsia-Pacific | Above thresholdGroup-level documentation is part of mandatory TP documentation where gross revenue for the basis period exceeds SGD 10 million, or documentation was required for the preceding basis period, subject to exemptions | Above thresholdGross revenue above SGD 10 million, or documentation required for the preceding basis period. Category exemptions: goods and loans SGD 15 million; services, royalties, rent, guarantees and other transactions SGD 1 million up to YA2025 and SGD 2 million from YA2026 | Kept, filed on request | TP documentation (group and entity level): Prepare by the filing due date of the tax return | RequiredConsolidated group revenue of at least SGD 1,125 million in the preceding financial year (Singapore-parented groups with foreign operations) | English, or translated into English | None |
| SlovakiaEurope | Above threshold | Above thresholdTiered (full, basic, short) by taxpayer and transaction size. | Kept, filed on request | TP documentation (on request): Within 15 days of request | RequiredEUR 750 million consolidated group revenue (Slovak-resident UPE) | Non-Slovak language accepted; tax administrator may request a Slovak translation within 15 days | Table I of the corporate income tax return (significant controlled transactions) |
| South AfricaAfrica | Above thresholdCompanies whose cross-border connected-party transactions (without offsetting) exceed or are expected to exceed ZAR 100 million, where the ultimate holding company is South African resident or a group entity has prepared a master file | Above thresholdAggregate potentially affected transactions (no offsetting) exceeding or reasonably expected to exceed ZAR 100 million | Filed separately | Local file: Within 12 months after the financial year end | RequiredZAR 10 billion consolidated group revenue | English | ITR14 section on cross-border transactions with connected persons |
| South KoreaAsia-Pacific | Above thresholdTurnover above KRW 100 billion in the taxable year and transactions with foreign related parties above KRW 50 billion (Decree Art. 34(1)) | Above thresholdTurnover above KRW 100 billion in the taxable year and transactions with foreign related parties above KRW 50 billion (Decree Art. 34(1)) | Filed separately | Master file and local file: Within 12 months after the end of the month in which the business year ends | RequiredKorean ultimate parent: consolidated turnover above KRW 1 trillion in the preceding taxable year; Korean entities of foreign-parented groups: the parent jurisdiction's threshold, or EUR 750 million where the parent has no filing obligation (Decree Art. 35(1)) | Master and local files in Korean; master file may be filed in English if a Korean version follows within one month; CbC report in Korean and English (Decree Arts. 34(3)-(4), 35(4)) | Statement of international transactions; Summary income statement of foreign related party; Report on the arm's length pricing method |
| SpainEurope | Above thresholdNot required for groups with revenue below EUR 45 million | RequiredSimplified content where revenue is below EUR 45 million; not required for transactions with the same related party under EUR 250,000 or within a tax consolidation group | Kept, filed on request | Master file and local file: Available from the end of the voluntary corporate tax filing period | RequiredConsolidated group net turnover above EUR 750 million at the start of the tax period | Not confirmed | Modelo 232 (related-party transactions information return) |
| Sri LankaAsia-Pacific | Above thresholdGroups with declared group revenue above EUR 50 million or the LKR equivalent (from year of assessment 2020/2021) | Above thresholdAggregate controlled transactions above LKR 200 million in a year of assessment | Kept, filed on request | Local file and master file: Within 60 calendar days of written request | RequiredConsolidated group revenue of EUR 750 million or more (or LKR equivalent) in the preceding fiscal year | English for the local file on international transactions; master file kept in English | Transfer Pricing Disclosure Form (TPDF) |
| SwedenEurope | Above thresholdNot required where the group, in the year before the tax year, has fewer than 250 employees and either turnover up to SEK 450 million or balance sheet up to SEK 400 million | Above thresholdSame SME exemption; transactions with a foreign related company under SEK 5,000,000 a year in total are treated as unimportant and need not be documented (not for intangibles unless unimportant) | Kept, filed on request | Local file: Prepared by the company's income tax return deadline | RequiredSEK 7 billion group revenue | Swedish, Danish, Norwegian or English | None |
| SwitzerlandEurope | Not requiredNo statutory master file requirement | Not requiredNo statutory local file requirement; under the general duty to cooperate, taxpayers must provide documents on request, including proof of arm's length pricing | Kept, filed on request | CbC report: Within 12 months after the reporting period end | RequiredCHF 900 million consolidated annual revenue (Swiss-resident parent) | No statutory TP documentation language rule (no statutory TP documentation) | None |
| TaiwanAsia-Pacific | Above thresholdExempt where full-year net operating plus non-operating revenue is below NTD 3 billion, or cross-border controlled transactions are below NTD 1.5 billion | Above thresholdTP report required for controlled transactions. Other documents proving arm's length results may replace it where total annual revenue is below NTD 300 million; where revenue is NTD 300 million to below NTD 500 million and further conditions are met (such as no tax incentives and no unused losses); or where total annual controlled transactions are below NTD 200 million | Kept, filed on request | TP report (local file): Ready when the annual income tax return is filed | RequiredPrior-year group consolidated revenue of NTD 27 billion or more | Chinese; foreign-language documents need a Chinese translation unless the tax authority approves English | Pages B2 to B6 of the annual profit-seeking enterprise income tax return (related-party structure chart, related-party list, transaction summary and details, MNE group member disclosure) |
| TanzaniaAfrica | Not confirmed | RequiredAll persons with controlled transactions. Where controlled transactions in a year of income meet the TZS 10 billion threshold, documentation is filed with the income tax return (Reg 7(3)(a)). | Filed with the return | TP documentation (TZS 10 billion threshold met): With the income tax return | Not confirmed | Swahili or English; other languages need translation by a translator approved by the Commissioner | None |
| TunisiaAfrica | Not confirmed | Not confirmed | Not confirmed | Annual transfer pricing declaration: Same deadline as the annual corporate income tax return | RequiredConsolidated annual revenue excluding taxes of TND 1,636 million in the prior year (Tunisian ultimate parent entity) | Not confirmed | Annual transfer pricing declaration (Déclaration sur les prix de transfert) |
| TürkiyeEurope | Above thresholdCorporate taxpayers in an MNE group whose total assets and net sales in the prior year's CIT return are both TRY 500 million or more | RequiredAnnual Transfer Pricing Report prepared by corporate income taxpayers | Kept, filed on request | Annual TP report (local file): Prepared by the annual CIT return deadline; submitted on request | RequiredEUR 750 million consolidated group revenue | Turkish. Documents prepared in another language need a Turkish version. | Transfer Pricing, Controlled Foreign Corporations and Thin Capitalisation Form; Annual APA Report (taxpayers with an APA) |
| UkraineEurope | Above thresholdOn request where the group's consolidated income for the prior financial year is at least the equivalent of EUR 50 million | Above thresholdTaxpayers with controlled transactions: annual income above UAH 150 million and transactions with each counterparty above UAH 10 million (net of indirect taxes) | Kept, filed on request | Local file (on request): Within 30 calendar days of request | RequiredGroup consolidated income above the equivalent of EUR 750 million for the prior financial year | Not confirmed | Report on controlled transactions; Notification of participation in an international group of companies |
| United Arab EmiratesMiddle East | Above thresholdRevenue in the tax period of AED 200,000,000 or more, or constituent company of an MNE group with consolidated group revenue of AED 3,150,000,000 or more | Above thresholdSame thresholds as the master file; certain transactions with UAE residents taxed at the same rate, independent natural persons and some partnership dealings are excluded | Kept, filed on request | Master file and local file: Within 30 days of an FTA request | RequiredAED 3,150,000,000 consolidated group revenue in the fiscal year before the reporting fiscal year | Not confirmed | Related party and connected person disclosure filed with the Corporate Tax return (Art. 55(1)) |
| United KingdomEurope | Above thresholdUK members of an MNE group within CbC reporting (consolidated group revenue of EUR 750 million or more) | Above thresholdUK entities of MNE groups at the CbC threshold (EUR 750 million) with material controlled transactions; HMRC accepts a GBP 1 million de minimis for each category of transactions. UK-to-UK transactions are excluded unless either party has a patent box election or a ring fence trade, and transactions covered by an APA made on or before 31 March 2023 are excluded. | Kept, filed on request | Master file and local file: Within the period in an HMRC information notice (generally 30 days) | RequiredEUR 750 million or more total consolidated group revenue | Not confirmed | International Controlled Transactions Schedule (ICTS), planned |
| United StatesNorth America | Not required | Above thresholdNo mandatory local file. Section 6662(e) documentation is needed for penalty protection. | Kept, filed on request | TP documentation (section 6662(e)): In existence when the return is filed; provide within 30 days of an IRS request | RequiredUSD 850 million revenue of the US MNE group in the preceding reporting period (US ultimate parent entities) | Not confirmed | Form 5472 (information return of a 25% foreign-owned US corporation or a foreign corporation engaged in a US trade or business); Form 8975 and Schedule A (country-by-country report) |
| UruguayLatin America & Caribbean | Above thresholdTaxpayers in multinational groups of large economic size (consolidated revenue of EUR 750,000,000 or more) | Above thresholdControlled transactions above 50 million indexed units (UI) in the year, or when notified by the DGI | Filed separately | TP sworn statement and local file: Within 9 months after fiscal year end | RequiredConsolidated group revenue of EUR 750,000,000 or more | Spanish; foreign documents must be translated and legalised; the CbC report may be in English or Spanish | Annual TP sworn statement with financial statements and local file |
| ZambiaAfrica | Not confirmed | Above thresholdPersons with annual turnover below K50 million need not prepare and maintain TP documentation (Reg 21(2), raised from K20 million for charge years from 31 Dec 2021); arm's length rules still apply | Not confirmed | CbC notification: By the last day of the reporting accounting year | RequiredConsolidated group revenue above K4.795 billion in the preceding accounting year (single kwacha threshold from 1 Jan 2023; previously EUR 750 million or K4.795 billion) | Not confirmed | None |
Download the global transfer pricing requirements (2026)
Every threshold, deadline and filing rule for 75 countries, in one CSV. It opens in Excel or Google Sheets.
WHAT WE SOLVE
Commenda's impact on global transfer pricing
We draft the policies and intercompany agreements, benchmark each arrangement against real comparables, and prepare the master file, local files and CbC report.
Then we track every deadline and file in each country, with a transfer pricing expert reviewing each document first.
OUR IMPACT
- 75
- countries' documentation rules checked against official sources
- 69
- of them require a local file, each with its own threshold and deadline
- 100+
- ERP and accounting integrations, so intercompany data flows in without exports
CROSS-BORDER GUIDES
Transfer pricing between two countries
Pick the two ends of the transaction and open the guide for that corridor. Each one covers both sides: what the parent's country asks for, and what the subsidiary's does.
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All 45 corridors
- Singapore to Australia transfer pricing
- Singapore to Canada transfer pricing
- Singapore to Germany transfer pricing
- Singapore to India transfer pricing
- Singapore to Japan transfer pricing
- Singapore to Netherlands transfer pricing
- Singapore to Switzerland transfer pricing
- Singapore to UK transfer pricing
- Singapore to USA transfer pricing
- USA to Australia transfer pricing
- USA to Belgium transfer pricing
- USA to Brazil transfer pricing
- USA to Canada transfer pricing
- USA to Cayman Islands transfer pricing
- USA to Germany transfer pricing
- USA to India transfer pricing
- USA to Ireland transfer pricing
- USA to Israel transfer pricing
- USA to Japan transfer pricing
- USA to Luxembourg transfer pricing
- USA to Malaysia transfer pricing
- USA to Mexico transfer pricing
- USA to Netherlands transfer pricing
- USA to Singapore transfer pricing
- USA to South Korea transfer pricing
- USA to Spain transfer pricing
- USA to Sweden transfer pricing
- USA to Switzerland transfer pricing
- USA to UAE transfer pricing
- USA to UK transfer pricing
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Master file and local file FAQs
What finance and tax teams ask about master file and local file requirements.
Both come from the OECD's BEPS Action 13 standard. The master file describes the whole group: its business, intangibles, financing and transfer pricing policies. The local file covers one entity and its intercompany transactions, with the functional analysis and benchmarking that support its prices. A country-by-country report is the third tier and reports revenue, profit and tax per jurisdiction.
59 of the 75 countries on this page ask for a master file, almost always once a revenue or transaction threshold is met. The threshold is set nationally and is usually well below the OECD's own figure. Germany asks for one at EUR 100 million of entity revenue in the preceding fiscal year. Each country row shows its threshold.
The OECD threshold for a country-by-country report is EUR 750 million of consolidated group revenue for the prior year. 35 of the 70 countries here that require a CbC report state that figure directly. The rest set it in local currency, and the amounts are not equivalent: the United States uses USD 850 million and the UAE uses AED 3.15 billion.
This is the first operational question and most pages skip it. In 48 of the 75 countries here the local file is prepared by a date and only handed to the tax authority when it asks, often within 30 days of the request. In 21 it is filed, either with the tax return or as a separate submission. The "Filed or kept" column says which applies.
52 of the 75 countries here state a language rule. Germany asks for German, will accept English where it is justified, and can require a German translation. Argentina asks for Spanish, with foreign-language documents translated by a sworn public translator. Australia accepts records that are in English or readily convertible into English.
The penalty is for the missing documentation itself, separate from any adjustment to the price. India charges 2% of the value of each transaction for not keeping the required documents, and INR 500,000 for not furnishing master file information. Germany can add a surcharge of up to EUR 1,000,000 for records submitted late, at a minimum of EUR 100 for each full day. In Australia an undocumented position is treated as not reasonably arguable, which raises the base penalty on any shortfall.
No. The United States has not written the master file or local file into domestic law. What it has is section 6662(e) documentation, which is not mandatory but is what protects you from the transfer pricing penalty on an adjustment. A US parent group files a country-by-country report on Form 8975 once group revenue reaches USD 850 million.
Of the 75 countries on this page, 69 require a local file and 59 require a master file, usually once a revenue or transaction threshold is met. 70 require a country-by-country report from the largest groups. The table carries every threshold, and 72 countries also have a full guide of their own, with the official source behind each figure.
Every country is checked against its tax authority, legislation or OECD country profile, and each page shows the date it was last verified. The most recent check was on 19 October 2026. Rules change often, so confirm the current position with your adviser before you file.
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