CMS Guide to International Transfer Pricing Documentation

08/09/2017

The Guide provides CMS’s international clients, particularly those having intra-group activities across Europe, Asia, the Maghreb region, Latin America, the US and the BRICs countries, with consistent and practical information of the documentation requested by each local tax authority.

The determination and verification of a transfer pricing policy involves the consideration of a range of information not necessarily contained in the documents that must be normally submitted to a tax authority. This specificity of transfer pricing, together with the fact that, generally, the tax authorities bear the burden of proof for making adjustments, has led various States to introduce specific documentation obligations in this context. These obligations are recent and undoubtedly reflect the increasing attention that the tax authorities are paying to transfer pricing. 
The Guide provides CMS’s international clients, particularly those having intra-group activities across Europe, Asia, the Maghreb region, Latin America, the US and the BRICs countries, with consistent and practical information of the documentation requested by each local tax authority.

This CMS brochure is an excellent support for international groups to manage and secure their transfer pricing policy in an environment where the provisions of national laws are far from being harmonised. 

Authors

Xavier Daluzeau
Partner
Picture of Valentin Lescroart
Valentin Lescroart
Associate
Picture of Annabelle Bailleul Mirabaud
Annabelle Bailleul-Mirabaud
Partner
Picture of Ivana Blagojević
Ivana Blagojević
Picture of Nebojsa Pejin
Nebojša Pejin
Picture of Anna Pogrebna
Anna Pogrebna
Partner
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