Paul Schmidt Comments to Bloomberg on Transfer Pricing "Master Files"

News / February 28, 2017

Partner Paul Schmidt is quoted in an article published Feb. 28, 2017, in Bloomberg BNA’s “Daily Tax Report.” The article, “Transfer Pricing ‘Master File’ Must Bow to Countries Rules,” discusses the Organization for Economic Development and Cooperation (OECD) recommendation that multinational companies submit a “master file” of transfer pricing documentation to various nations where they do business. Corporate tax departments for those companies have noted that this practice has mushroomed into time-consuming country-specific documentation.

Schmidt, who is extensively quoted throughout the article, told Bloomberg that a master file “is a narrative that puts the pieces of a taxpayer's transfer pricing puzzle together in one place” and taxpayers are well advised to construct the document with great precision and balance. “I fully expect corporate tax directors to pay close attention to the ‘art’ of describing the functions and risks and their company's overall transfer pricing policy and to scrutinize the master file both for what it says and doesn't say.”

Read the article (registration required).

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