Development and Evaluation of Regulations concerning Transfer Pricing Documentation
DOI:
https://doi.org/10.33119/ASCASP.2018.2.2Keywords:
TP documentation master file, local file benchmarking analysisAbstract
The new regulations that have been introduced since 2017 extend significantly the scope of the TP documentation and reporting requirements to be provided to tax authorities. Therefore they increase administrative and financial burden in particular for multinational enterprises. Taxpayers should prepare for next changes (2019) by i.a. assessing the necessary resources to complete the extended reporting requirements and developing revised standards of intercompany TP documentation (master file, local file, benchmarking analysis). As a consequence, the preparation of TP documentation should no longer be regarded as a purely compliance exercise but instead should become an inherent part of the capital group’s tax risk management.
References
Jamroży M., Dokumentacja podatkowa cen transferowych, Gdańsk 2017
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