local file

A mandatory element of transfer pricing documentation is the local file for each local member company. In terms of content the local file is similar to the stand-alone transfer pricing documentation prepared under the previous transfer pricing regulation. However, this document should already contain a number of additional elements that were previously not a part of the documentation. Such details include for example the description of the management structure or the decision-making and reporting processes. The preparation of the local document is in all cases the responsibility of the local member company.