All rules are current as of November 2010.
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.
Transfer pricing methods allowed, as well as 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.
Potential ways in which penalties may be reduced or avoided.
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.
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. This is based on the past experience of our local tax professionals and is not a forward looking prediction.
Discussion of the availability of obtaining an advance pricing agreement with the tax authority.
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