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Expert Guide 14 Nov 2024 (UPDATED: 12 Nov 2025) · International

CMS Expert Guide to Transfer Pricing Documentation

2 min read · Comparable

Welcome to our Expert Guide on Transfer Pricing Documentation requirement. In today's global business environment, understanding and complying with transfer pricing rules is crucial for multinational enterprises to avoid penalties and ensure tax compliance. 

This guide summarises key information from multiple countries based on a standardised questionnaire. It offers a clear overview of the essential transfer pricing documentation obligations you need to be aware of. 

What You'll Find

  • Transfer Pricing Documentation: An outline of who is required to maintain documentation, what it should contain, and its alignment with EU and OECD guidelines.
  • Country-by-Country Reporting (CbCR): Information on the implementation status, filing requirements, and compliance with international standards.
  • Additional Requirements: Details on any other local documentation obligations and associated penalties.

How This Guide Helps You

  • Simplify Compliance: Quickly grasp the documentation requirements in different jurisdictions.
  • Facilitate Comparison: Easily compare and contrast transfer pricing rules across countries.
  • Stay Informed: Keep up-to-date with the latest developments in international transfer pricing regulations.

We hope this guide assists you in navigating the complexities of transfer pricing documentation worldwide. By consolidating essential information directly from various jurisdictions, we aim to support your compliance efforts, reduce the risk of non-compliance, and promote transparency in international business operations.


Please note that this Guide does not cover the specific obligations regarding the EU public Country-by-Country Reporting (EU public CbCR). As such, Member States have transposted these obligations into national legislation with several differences regarding implementation, timing and exceptions from the original Directive that was published in the EU Official Journal on December 1, 2021. In order to asses if you are bound by any of the obligations regarding the EU public CbCR, we recommend you get in touch with your local CMS advisors.



Last updated · 12 Nov 2025
Tax
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