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2010 Transfer pricing global reference guide - Transfer pricing legend - Ernst & Young - Global

2010 Transfer pricing global reference guide

Transfer pricing legend

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All rules are current as of  November 2009.

Taxing authority and tax law:
Name of taxing authority and statutory provisions currently in effect in each country.

Relevant regulations and rulings:
Current transfer pricing rules and regulatory provisions in effect in each country.

OECD guidelines treatment:
Consideration given by the taxing authority to the OECD Transfer Pricing Guidelines. Priorities/pricing methods : Transfer pricing methods allowed, and the priority of each method.

Transfer pricing penalties:
Discussion of potentially applicable transfer pricing penalties if a taxpayer is determined not to be in compliance with the rules imposed by the taxing authority.

Penalty relief:
Potential ways in which penalties may be reduced or avoided.

Documentation requirements:
Governing tax authority requirements or recommendations that taxpayers prepare and maintain written documentation to confirm that the amounts charged in related-party transactions are consistent with the arm’s length standard.

Documentation deadlines:
Deadline for preparing transfer pricing documentation.

Statute of limitations on transfer pricing assessments: 
Discussion of applicable statute of limitations regarding transfer pricing examination and assessments.

Return disclosures/related-party disclosures: 
Information on disclosures required by taxpayers regarding related party transactions.

Audit risk/transfer pricing scrutiny: 
Discussion of the level of risk for the tax authority scrutinizing related party transactions.

APA opportunity:
Discussion of the availability of obtaining an advance pricing agreement with the tax authority.

 

 

 

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