This framework Master file is written for a centralized multinational group.

This framework report Master file is typically used for a multinational group with a centralized organizational structure. The framework report documents a situation for one or more contract manufacturers and multiple limited risk distributors that operate on the basis of instructions from and under the supervision of a principal company. In this framework report, the principal company sets the strategy for the group, is the owner of the intellectual property of the group and is ultimately responsible for all product development, production, and sales. It also incurs almost all risks relating to the operations of the group.

Apart from the sales transactions in which principal, the contract manufacturers and the limited risks distributors are engaged in, this framework report also captures the following intercompany transactions; i) rendering of head office services, ii) granting of access to patents and know-how and iii) provision of loans. To facilitate your documentation efforts for said intercompany transactions, we included ample sample wording.

The framework report is set up in line with the latest OECD BEPS requirements (i.e. Action 13) and contains the required content and technical language. The framework report also provides comprehensive guidance enabling you to tailor the framework report to the specific situation of your group and where to typically find specific information.