While it is certainly difficult for MNEs to isolate digital ser- vices from the remaining related-party supplies, the recent changes to the transfer pricing framework compel such compa- nies to implement functional segmentation and to keep robust, supporting documentation. The ARS is carefully ...
International Transfer Pricing in action TP documentation powered by technology Evolving implications from the OECD's Action 13 guidance are challenging businesses to find more efficient, centralized and integrated ways to plan and manage TP documentation processes. Tax audit activity is on the rise as...
2019/1 which addresses its transfer pricing compliance approach to inbound distributors; the Vietnam tax authority announced that it has distributed a list to its provincial tax departments of companies that should be subject to transfer pricing audit in 2019; and Duff & Phelps' Canadian Transfer ...
Amended transfer pricing documentation and reporting requirements are applicable in Poland, generally with effect from 1 January 2019. These changes are expected to further increase the compliance burden for big multinational businesses and lessen the burdens for, in particular, small and medium-sized en...
When resolved, why not also explore recasting or “memorializing” the audit result into an APA and securing lasting benefits? Or perhaps even consider a bilateral or multilateral APA for added security and consistency? All these potential benefits can be derived from essentially standardizing, ...
1.2. Practical context In order to assist taxpayers manage their Australian transfer pricing obligations, the ATO has issued a number of practical compliance guidelines (PCGs). These are intended to provide a framework to convey to taxpayers the ATO's assessment of relative levels of tax compliance...
Many tax authorities think TP data requested for an audit can be easily produced and often expect responses within thirty days. Taxpayers find the requested data is unavailable, inaccurate, or incomplete. Files are saved in an ad hoc manner (e.g., by country or employee) with no ability to...
TRANSFER PRICING PENALTIES No specific regulations. During a tax inspection, tax audit adjustments may be carried out because of a discrepancy from arm's length principle (ALP). A penalty is only possible if there is proof of fraudulent intent. In some areas (e.g. documentation), gross ...
It has been more than three years since the framework of the transfer pricing law was first drafted and approved by the Cabinet of Thailand in May 2015, write Benjamas Kullakattimas, Abhisit Pinmaneekul and Chollatip Santitorn of KPMG.
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