Transfer pricing documentation requirements due to changeMichiel Els
How to cope with the increased transparency and disclosure requirements? With an efficient, consistent framework to produce the documentation required to defend your transfer pricing policy. You need to know where to focus your efforts efficiently and to ensure all specific local-country tax authority...
Documentation requirements in Namibia Paragraph 8 of PN2/2006 requires that a taxpayer be in possession of transfer pricing documentation. The taxpayer must be able to demonstrate that they have developed a sound transfer pricing policy in terms of which transfer prices are determined in accordance ...
What are the documentation requirements for transfer pricing in Indonesia? Indonesia followsAction Plan 13of theBase Erosion and Profit Shifting (BEPS)initiative. Taxpayers must prepareannual transfer pricing documentationthat is contemporaneous and adhere to Indonesia’s local jurisdiction regulations. The D...
Dealing on a Global Basis with Transfer Pricing Documentation RequirementsLevey, Marc
The Indian government has proposed to introduce three-layered transfer pricing documentation requirements.Taxpayers will now be required to prepare a master file, local file, and country-by-country (CbC) reporting.While the detailed contents of these documents is provided through rules, the reporting ...
enterprises operating in India. The regulations are broadly based on the Organisation for Economic Co-operation and Development (OECD) Guidelines and describe the various transfer pricing methods, impose extensive annual transfer pricing documentation requirements, and contain harsh penal provisions for non...
This coupled with increased tax authority collaboration across borders presents both risks and opportunities. Deloitte provides practical solutions such as strategic approaches to transfer pricing documentation requirements, which help global businesses to achieve their operational and international tax objectives...
Tax authorities worldwide are imposing new, stricter reporting and documentation requirements on transfer pricing arrangements. The OECD recently published recommendations as part of its Base Erosion and Profit Shifting (“BEPS”) initiative and Vietnam have been quick to introduce many of these recommen...
point of discord between multinational companies and tax authorities like theInternal Revenue Service (IRS). For example, the IRS has implemented strict documentation requirements for transfer pricing to ensure compliance and reduce tax avoidance; taxpayers must provide pricing documentation to avoid ...