Transfer pricing newsletter - May 2015

Practical consequences of not having a transfer pricing documentation

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.

CMS Transfer Pricing Team

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

Publications

Brochures

• Master Domestic and International tax matters
• Transfer Pricing | A strategic approach for global business performance

E-Guide 

• Tax Connect Guide | Transfer Pricing: Managing documentation requirements in 30 countries

Tax Connect Flash on Transfer pricing 

• BEPS - First steps in the implementation of the Country-by Country reporting | Tax Connect Flash  (March 2015) 
• France – New regulations in relation with transfer pricing | Tax Connect Flash (February 2014)

Read Transfer Pricing Newsletter on Practical consequences of not having a transfer pricing documentation