The master file shall provide an overview of an Multinational Enterprise (MNE)’s global operations, its overall transfer pricing policies for the creation and ownership of intangibles and its financial activities, and its global allocation of income and economic activity to place the MNE’s transfer pricing practices in their global economic, legal, financial, and tax context.

The Local File shall provide an analysis for related party transactions which specifically consist of material transactions of the Company.

Country-by-Country Report shall provide certain information relating to the global allocation of the MNE’s income and taxes paid together with certain indicators of the location economics activities within the MNE group.