Transfer Pricing Brochure: International Documentation Requirements

Many companies view transfer pricing documentation requirements as a bureaucratic burden and generally attach little importance to them. At the latest in the event of a tax audit, this assessment regularly results in considerable non-compliance costs. Our many years of experience show that, in tax audits worldwide, transfer pricing documentation that is prepared on time, is correct in terms of content and is coordinated within the group of companies remains the key to minimising these costs.

A necessary prerequisite for this is, first of all, knowledge of the legal deadlines, which not only concern the submission of all necessary documentation, but may also include possible notification requirements or similar.

Most nation states have now incorporated the three-tier documentation approach into their national legislation. Contrary to the basic idea of standardisation, there are also a number of local peculiarities and deviations that must be taken into account separately in the context of transfer pricing documentation. In addition, the introduction of Public Country-by-Country reporting has led to even greater transparency in terms of information and taxation, which also extends to public access to sensitive tax data. It is therefore still advisable to view transfer pricing not only as a compliance task, but also as an opportunity to present your own group of companies to all stakeholders.

With this publication, we would like to provide you with some guidance by presenting an overview of all relevant deadlines and provisions in more than 60 countries.

We shape the future. For your Transfer Pricing Compliance.

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Nilanjan Nag

Head of Transfer Pricing and Tax Strategy

+370 5 212 35 90

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