All rules are current as of 29 February 2012 unless otherwise noted. This publication should not be regarded as offering a complete explanation of the tax matters referred to and is subject to changes in the law and other applicable rules.
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.
Organisation for Economic Co-operation and Development Guidelines treatment:
consideration given by the taxing authority to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
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 the applicable statute of limitations regarding transfer pricing examination and assessments.
Return disclosures/related party disclosures:
information on disclosures required from taxpayers regarding related party transactions.
Audit risk/transfer pricing scrutiny:
discussion of the level of risk of the tax authority subjecting taxpayers to general audits, scrutinizing related party transactions and challenging the transfer pricing methodology employed. This is based on the past experience of our local tax professionals and is not a forward-looking prediction.
discussion of the possibility of obtaining an advance pricing agreement with the tax authority.
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