Worldwide transfer pricing reference guide 2014

The content is current as of 28 February 2014 unless otherwise noted. This publication should not be regarded
as offering a complete explanation of the tax matters referred to and is subject to changes in the law and other
applicable rules.
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Taxing authority and tax law: name of taxing authority and statutory provisions currently in effect in each
jurisdiction.
Relevant regulations and rulings: current transfer pricing rules and regulatory provisions in effect in each
jurisdiction.
OECD Guidelines treatment: consideration given by the taxing authority to the OECD Transfer Pricing Guidelines
for Multinational Enterprises and Tax Administrations.
Priorities/pricing methods: transfer pricing methods allowed, as well as the priority of each method.
Transfer pricing penalties: discussion of potentially applicable transfer pricing penalties if a taxpayer is determined
not to be in compliance with the rules imposed by the taxing authority.
Penalty relief: potential ways in which penalties may be reduced or avoided.
Documentation requirements: governing tax authority requirements or recommendations that taxpayers prepare
and maintain written documentation to confirm that the amounts charged in related party transactions are
consistent with the arm’s length standard.
Documentation deadlines: deadline for preparing transfer pricing documentation.
Statute of limitations on transfer pricing assessments: discussion of the applicable statute of limitations
regarding transfer pricing examination and assessments.
Return disclosures/related party disclosures: information on disclosures required from taxpayers regarding
related party transactions.
Frequency of tax Audits/transfer pricing scrutiny: discussion of the level of frequency of the tax authority
subjecting taxpayers to general audits, scrutinizing related party transactions and challenging the transfer pricing
methodology employed. This is based on the past experience of our local tax professionals and is not a forwardlooking
prediction.
APA opportunity: discussion of the possibility of obtaining an advance pricing agreement with the tax authority.
Expected reaction to OECD Report on BEPS: perspective on initiated or expected reactions in the respective
legislation to the OECD Report on BEPS.
Worldwide transfer pricing reference guide
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