Transfer pricing documentation

Having adequate transfer pricing documentation available helps to prevent companies being confronted with a shift of the burden of proof with respect to transfer pricing adjustments imposed by tax authorities, as well as double taxation. Moreover, non-compliance with transfer pricing documentation requirements can sometimes lead to penalties. Multinationale Unternehmen arbeiten in einem Umfel das durch zunehmende Komplexität geprägt ist.

Das steigende Volumen, die Quantität an Transaktionen zwischen verbundenen Unternehmen sowie die Vielzahl staatlicher Verrechnungspreisregelungen, die von verstärkten Prüfungsaktivitäten weltweit begleitet werden, haben die Einhaltung der Verrechnungspreisregelungen zu einem der wichtigsten Risikomanagement-Themen für global agierende Firmen werden lassen. The requirements for transfer pricing documentation are therefore increasing.

In particular, companies must pay a lot of attention to documenting that their transfer pricing arrangements are arm´s length. This makes the preparation of transfer pricing documentation also a process issue where companies should consider costs and efficiency. Transfer pricing is on the internal audit and board agenda more than ever. In many jurisdictions, external auditors will request to see transfer pricing documentation when signing off financial. WHITE PAPER ON TRANSFER PRICING DOCUMENTATION Over the last years, transfer pricing documentation requirements have rapidly spread around the world.

This trend continues every year with new additions to the list of countries requiring preparation of transfer pricing documentation. The proliferation of diverse local transfer pricing.

Practitioners need to have current knowledge of a complex web of jurisdiction tax laws, regulations, rulings, methods and requirements. Now, TPS shares its know-how with you! For accessing a template of the transfer pricing documentation file just click here.

OECD- Her finder du bl. EU Joint Transfer Pricing Forum (JTPF) - Her finder du information om møder, medlemmer og skrivelser i Joint Transfer Pricing. Standards, Microbiology and more. The formal requirements under German law are fairly detailed and complex. A full description would go beyond the scope of this.

This topic was addressed on two occasions by the JTPF: when a Forum member, Professor Maisto, conducted a study to better assess how penalties were addressed by EU Member States, and when the JTPF discussed transfer pricing documentation requirements. Tax governance and control. If not, the Singapore company may need to supplement it with other documentation or analysis, taking into consideration its tax risks and compliance costs.

The Dutch transfer pricing legislation does not give a clear indication as to exactly what the minimum requirements are in terms of transfer pricing documentation. The content of the file must be according to the local legislation. Kompetenz in Transfer Pricing. Das Thema Transfer Pricing wird in Zeiten zunehmender Internationalisierung immer wichtiger.

Zur Erfüllung rechtlicher Vorschriften ist professionelle Beratung im Bereich Verrechnungspreise für multinationale Unternehmen unverzichtbar.

The successful documentation exercise is more than pure compliance to mitigate tax exposures. The BURDENSOME PROCESS of documentation currently asks for multiple tiers of documentation (Master File, Local File, Country-by-Country Report, and local information returns), which you should harmonise. These files and reports will provide tax authorities with a detailed description of the MNE and an in depth analysis of prices and terms applied to controlled transactions.

But, where to start, what to prioritize and how to manage the local complexities and nuances of the. That is in itself a sound basis to take the position that the transfer pricing is at arm’s length. The last step would be to determine whether transfer pricing documentation needs to be prepared. This depends on steps and but also on local legislation. For example, in Vietnam a company is exempted from preparing transfer pricing.

The Danish Transfer Pricing Rules The Danish tax rules require that affiliated companies transact with each other on the same terms and conditions that they apply to unrelated parties. This is known as the “arm’s-length principle”.