While ideally taxpayers will use transfer pricing documentation as an opportunity to articulate a well thought-out basis for their transfer pricing policies, thereby meeting an important objective of such requirements, issues such as costs, time constraints, and competing demands for the attention of relevant personnel can sometimes undermine these objectives. It is therefore important for countries to keep documentation requirements reasonable and focused on material transactions in order to ensure mindful attention to the most important matters.
TPG2022 Chapter V paragraph 5.9
Category: B. Objectives of transfer pricing documentation requirements | Tag: Administrative-/compliance burden, Compliance costs, Transfer pricing documentation
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Next » Related Guidelines
- TPG2022 Chapter V paragraph 5.14In situations where a proper transfer pricing risk assessment suggests that a thorough transfer pricing audit is warranted with regard to one or more issues, it is clearly the case that the tax administration must have the ability to obtain, within a reasonable...
- TPG2022 Chapter V paragraph 5.3Since then, many jurisdictions have adopted transfer pricing documentation rules and the proliferation of these requirements, combined with a sharp increase in the volume and complexity of international intra- group trade and the heightened scrutiny of transfer pricing issues by tax administrations, has...
- TPG2022 Chapter V paragraph 5.2This chapter provides guidance for tax administrations to take into account in developing rules and/or procedures on documentation to be obtained from taxpayers in connection with a transfer pricing enquiry or risk assessment. It also provides guidance to assist taxpayers in identifying documentation...
Related Case Law
- Mexico vs “TP doc-Lawsuit”, June 2019, Supreme Court, Case No. 14039/17-17-10-3/2502/18-PL-07-04In this case a group of taxpayers filed a lawsuit for the nullity of the new Mexican transfer pricing documentation obligations introduced in 2017 by rules 3.9.11, 3.9.14, 3.9.15, 3.9.16 and 3.9.17 of the First Resolution of Amendments to the Tax Miscellaneous published...