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.

Priorities/pricing methods:
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.

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. This is based on the past experience of our local tax professionals and is not a forward looking prediction.

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

<< Previous | Next >>