In line with the guidelines developed as part of Action 13 of the OECD BEPS Project, Macau has introduced transfer pricing documentation requirements consisting of the Master file and the Local file for fiscal years beginning on or after 1 January 2019. The documentation requirements apply to ultimate parent entities of MNE groups in Macau, meeting an annual consolidated revenue threshold of MOP 7 billion in the preceding year.

When the threshold is met, a notification on the obligation and the preparation of the documentation must be submitted to the Financial Services Bureau within 3 months after the end of the reporting fiscal year.

All documentation must be retained for a period of at least 7 years after the end of the reporting fiscal year.

Country-by-Country (CbC) Reporting

The ultimate parent entity of an MNE group in Macau is required to file a Country-by-Country (CbC) report for fiscal years beginning on or after 1 January 2019 if the MNE group meets the annual consolidated revenue of the threshold of MOP 7 billion in the preceding year. There is no local filing requirement in Macau.

The CbC report must be retained for a period of at least 7 years after the end of the reporting fiscal year.

The CbC report is required to be submitted electronically within 12 months after the last day of the reporting fiscal year.

Penalties

Failure to comply with the documentation and notification obligations may attract fines ranging from MOP 100 to MOP 10,000. Where the offense is intentional, the fines can be increased up to between  MOP 1,000 and MOP 20,000.