2016-17 Worldwide Transfer Pricing Reference Guide

This guide summarizes the transfer pricing rules and regulations adopted by 118 countries and territories. Use the map or the menu to see the guide’s information for a jurisdiction.

This guide summarizes the transfer pricing rules and regulations adopted by 118 countries and territories. Use the menu to see the guide’s information for a jurisdiction.

 
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Transfer pricing rules and regulations around the world continue to grow in number and in complexity. Practitioners need to have current knowledge of a complex web of country tax laws, regulations, rulings, methods and requirements.

The EY Worldwide Transfer Pricing Global Reference Guide is a tool designed to help international tax executives quickly identify transfer pricing rules, practices and approaches. These must be understood in order for a company to carry out both compliance and planning activities. The information included in the guide now covers 118 countries and territories in which EY offers Transfer Pricing services. Countries appearing in the guide for the first time are: Belarus, Cape Verde, Madagascar, Malawi and Zambia.

The transfer pricing global reference guide is meant to provide an overview for the covered jurisdictions regarding their transfer pricing tax laws, regulations and rulings; Organisation for Economic Co-operation and Development (OECD) guidelines treatment, priorities and pricing methods; penalties; the potential for relief from penalties; documentation requirements and deadlines; statute of limitations; required disclosures; transfer pricing-specific returns; frequency of tax audits and transfer pricing scrutiny by the tax authority; and opportunities for advance pricing agreements (APAs).

In 2015, the OECD released final reports on all 15 focus areas in its Action Plan on Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory statement, the OECD described the next steps in its work on BEPS, including additional work on technical matters and plans for monitoring with respect to the implementation of the BEPS recommendations.

In conjunction with the release of the reports, the OECD held a press conference followed by a technical briefing, both by webcast, to provide an overview of the final BEPS output. There has been continued updates on the action items. We have covered the reaction to the finalized Actions 8 through 10 at the time of publication.

For a more detailed discussion of any of the country-specific transfer pricing rules, or to obtain further assistance in addressing and resolving intercompany transfer pricing issues, please contact your local EY office or the relevant jurisdiction contact listed on the country page.

Please note the availability of other transfer pricing materials such as survey reports that share views of tax authorities and tax directors. EY also annually produces the Worldwide Corporate Tax Guide, the Worldwide Personal Tax Guide and the Worldwide VAT, GST and Sales Tax Guide.


The content is correct as of 15 August 2016 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.