With the introduction by the OECD transfer pricing documentation concept consisting of a Master File, Local Files and a Country-by-Country Report ("CbCR"), many corporates are now confronted with how to ensure compliance with these new requirements in multiple countries every year. At the heart of these processes are a series of annual updates required for benchmarking and other data points. Questro is regularly involved in large-scale documentation projects which involve the establishment and updating of a large number of benchmarks. Effective and pragmatic management of this process, whilst ensuring high quality outputs, is a key factor in mitigating future contentious local tax audits. Unfortunately, not all benchmarking is the same, and the cheapest option is often significantly more expensive in the long run.

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