These studies are key for showing that related-party transactions use market prices, thereby reducing tax risk and supporting tax efficiency.
Local File
- The Local File is mandatory for companies that meet one of the following thresholds:
If they exceed €250,000 in specific transactions with related parties in a financial year - Required for transactions with tax havens regardless of amount.
Our team ensures that all significant transactions between related parties at a local level are justified. We analyse the functions, risks and assets involved in transactions to ensure that the prices applied fulfil market conditions, in accordance with the Corporate Tax Act and OECD guidelines.
Master File
The Master File is mandatory for groups whose consolidated turnover exceeded €45 million in the previous year.
How useful is this information for the company?
This documentation provides an overall view of the corporate group and its transfer pricing policies, describing its organisational structure, functions, risks undertaken by each group entity, and significant international transactions. A master file is developed in fulfilment of national and international regulations to ensure that your company is adequately prepared for any inspections or tax audits.
- Comparability or benchmark studies: These are a key tool to verify that related-party prices accord with market conditions.
- Additional recommendations: In addition to preparing the required documentation, we include recommendations for optimizing the transfer pricing structure and/or correcting inefficiencies.
How useful is this information for the company?
A transfer pricing study not only allows for compliance across jurisdictions, but constitutes a key tool for minimizing the risk of penalties or fines by tax agencies.
From a strategic perspective, such a report also adds value by identifying market ranges and acceptable margins, which supports the design of efficient intragroup policies aligned with economic reality. This results in improved financial planning, greater international cohesion in the pricing policy and robust support for decision-making in multinational structures.
In Mexico the rules apply to every related-party transaction (approx. €1) with no minimum threshold. Transactions are reported in the Declaración Informativa Múltiple with the annual return. Some groups also have BEPS (Local File, Master File and country-by-country) obligations.
- Mexico
In Colombia an information return is required when gross assets are at least approximately €864,000 or gross revenue reaches €527,000. It is always required for non-cooperative or low-tax jurisdictions, regardless of the above thresholds.
- Local File: related transactions above approximately €490,000.
- Master File: when the taxpayer also belongs to a multinational group.
- Colombia
In Brazil the rules apply to every international transaction (approx. €1) with related parties or entities in low- or zero-tax jurisdictions, with no minimum threshold.
- Brazil
In Portugal formal documentation on transfer pricing is not mandatory below approximately €10 million annual turnover. Related-party transactions must still be reported in Modelo 22 and the annual IES, and the authorities may request proof of the arm’s-length principle in the event of an inspection.
- Portugal
In Chile the affidavit Declaración Jurada 1907 is required for medium or large companies (>€0) or when transactions with foreign entities exceed approximately €480,000.
- Chile
In Ecuador obligations depend on related-party volume: above approximately €2.7–2.8 million the addendum is filed; above €13–14 million the comprehensive report and addendum are filed.
- Ecuador
In Peru the Local Report is required when revenue exceeds approximately €2.6 million and related-party transactions exceed €115,000. Its content varies with transaction volume.
- Peru
In the United States documentation is not mandatory but is advisable to protect against penalties. If requested by the IRS, the taxpayer has 30 days to respond.
Form 5472 is mandatory under Section 6038A for US corporations that are at least 25% foreign-owned, in order to report related-party transactions on an annual basis. Each failure to file carries a USD 25,000 penalty and may lead to operational consequences such as EIN suspension, even if the entity has no economic activity.
Groups above €750 million turnover must also file a Country-by-Country Report.
- United States
