The Resource Global focus on transparency - transfer pricing documentation and audits

Global focus on transparency - transfer pricing documentation and audits

Label
Global focus on transparency - transfer pricing documentation and audits
Title
Global focus on transparency - transfer pricing documentation and audits
Subject
Language
eng
Summary
The past few years have seen many changes with respect to transfer pricing documentation, from the new country-by-country reporting (CbC) reporting rules to Master File/Local File requirements to tax return disclosures. This forum explores the impact that this increased global focus on transparency has had on the transfer pricing compliance process and the audit process. Respondents were asked to discuss challenges taxpayers face in preparing the detailed documentation required, as well as the ways tax authorities are adapting to the increased level of information available to them. QUESTIONS: 1. Briefly describe the transfer pricing documentation and tax return disclosure requirements in your jurisdiction; 2. In recent years, have the tax authorities changed or modified their audit approach? (e.g., increase in staffing and/or increase in funding with respect to the transfer pricing audit function; use of risk assessment tools or data mining tools to identify audit targets; use of joint or coordinated audits, etc.). If risk assessment tools are used, what factors are typically analyzed?; 3. Do the tax authorities focus on certain types of transactions? (e.g., intangibles, financing transactions, commodities, etc.); 4. Do the tax authorities rely on BEPS-related concepts during its audits? (e.g., DEMPE analysis, new approach for hard-to-value intangibles, expanded use of profit splits, use of risk assessment framework, etc.); 5. Do transfer pricing penalties apply in your jurisdiction? If so, what can be done to mitigate these penalties?; 6. Please describe any challenges taxpayers face in preparing their transfer pricing documentation in light of these changes in the audit process
Citation source
In: Transfer pricing forum. - Arlington. - Vol. 10 (2019), no. 1 (April) ; 115 p
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • documentation requirements
  • CbCR
  • master file
  • local file
  • transparency
  • audit
  • joint audit
  • disclosure
  • tax authorities
  • risk assessment
  • intangibles
  • penalties
Label
Global focus on transparency - transfer pricing documentation and audits
Instantiates
Publication
Label
Global focus on transparency - transfer pricing documentation and audits
Publication

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