Practices regarding the timing of the preparation of the documentation differ among countries. Some countries require information to be finalised by the time the tax return is filed. Others require documentation to be in place by the time the audit commences. There is also a variety in practice regarding the amount of time given to taxpayers to respond to specific tax administration requests for documentation and other audit related information requests. These differences in the time requirements for providing information can add to taxpayers’ difficulties in setting priorities and in providing the right information to the tax administrations at the right time
TPG2017 Chapter V paragraph 5.29
Category: D. Compliance issues, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter V: Documentation | Tag: Contemporaneous documentation, Time frame documentation
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