The master file should provide an overview of an 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 guidance requires that the local file contains much of the same information that was traditionally found in transfer pricing documentation related to the local entity, including its controlled transactions and financial data. Although the local file will be centered on a traditional functional and economic analysis, the guidelines are more prescriptive than the documentation rules in many countries, and require additional details not required or contained in many documentation reports. While the master file provides a high-level overview, the local file should provide more detailed information relating to specific material intercompany transactions.

Country-by-Country Reporting (CbCR) is part of the OECD's Base Erosion and Profit Shifting (BEPS) Action Plan 13.
In essence, large multinationals have to provide an annual report, the CbC Report, that breaks down key elements of the financial statements by jurisdiction. A CbC Report provides local tax authorities visibility to revenue, income, tax paid and accrued, employment, capital, retained earnings, tangible assets and activities.
CbCR provides tax authorities information to help them assess transfer pricing risks and make determinations on how they allocate tax audit resources.