Transfer pricing newsletter - April 2015

Global

While transfer pricing documentation requirement is not a new issue, it remains more than ever topical. Over the last years, many countries introduced more stringent regulations in that framework. Furthermore, Action 13 of BEPS is about re-examining transfer pricing documentation. Action 13 aims at developing rules regarding transfer pricing documentation to enhance transparency for tax administrations.

In this context which claims for increased documentation obligations, practical consequences of not having a transfer pricing documentation are described for several jurisdictions.