Introduction to Master File and Country by Country Report:
The lack of quality data on corporate taxation has been a major limitation to measuring the fiscal and economic effects of tax avoidance, making it difficult for authorities to carry out transfer pricing assessments on transactions between related companies and even more difficult to carry out audits.
To tackle the above issue and to provide tax authorities with sufficient information about economic activities of multinational group, OECD[1] has prepared Action Plan 13 under the BEPS[2] Package. Action Plan 13 requires every multinational group to file a detailed report namely ‘Country by Country Report’ (‘CbCr’) on its economic activities to tax authorities.