Prac­tic­al con­sequences of not hav­ing a trans­fer pri­cing doc­u­ment­a­tion

02/05/2015

While transfer pricing documentation requirement is not a new issue, it remains more than ever topical. Over the last years, many countries introduced more stringent regulations in that framework. Furthermore, Action 13 of BEPS is about re-examining transfer pricing documentation. Action 13 aims at developing rules regarding transfer pricing documentation to enhance transparency for tax administrations.

In this context which claims for increased documentation obligations, practical consequences of not having a transfer pricing documentation are described for several jurisdictions.

Focus

  • France
    Practical consequences of not having a transfer pricing documentation
  • Germany
    Practical consequences of not having any transfer pricing documentation
  • Italy
    Practical consequences of not having any transfer pricing documentation
  • Romania 
    Practical consequences of not having transfer pricing documentation
  • Spain
    The importance of documentation of transactions between related parties

Hot topics

  • Africa
    Africa and Transfer Pricing: an ongoing construction
  • Germany
    New German regulations on the allocation of profits to permanent establishments
  • Italy 
    Hot topics on transfer pricing
  • Switzerland
    Safe harbour interest rates on down-stream intra-group loans 2015
Source
CMS Transfer Pricing Newsletter - May 2015
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Authors

Bailly Benoît
Benoit Bailly
Partner
Paris
Picture of Giovanni Battista Cali
Giovanni Cali
Partner
Rome
Xavier Daluzeau
Xavier Daluzeau
Partner
Paris
Picture of Valentin Lescroart
Valentin Lescroart
Counsel
Paris
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