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
