The determination and verification of a transfer pricing policy involve 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 Expert 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 guide is 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.