As the year draws to a close, companies are preparing their final accounts for 2024. Now is the last opportunity to carefully review and make any necessary adjustments to settlements, pricing, or contract terms. The adjustments themselves continue to raise numerous interpretative questions, not only about their definition but also regarding the conditions for their…
Transfer pricing is essential for both businesses and tax authorities, as it involves setting prices for transactions between related parties, where there may be a risk of under-reporting income in one of the jurisdictions. For this reason, it’s important to ensure these prices are correctly determined, and then properly verified. In this post, we outline…
This is one of the key tools tax authorities use to verify transactions between related parties. With the TPR form deadline approaching, here’s a reminder of the essentials of transfer pricing reporting: What transfer pricing information is, What data it includes, Who is required to submit it, Who is liable for failure to submit, What…
The deadlines for meeting transfer pricing obligations for 2023 are fast approaching, especially for taxpayers whose fiscal year aligns with the calendar year: by October 31, local transfer pricing documentation must be prepared. by November 30, transfer pricing information must be submitted using form TPR-C. In this post, we address common questions surrounding the submission…
A comparative analysis, also referred to as a transfer pricing benchmark, is essential for: establishing transfer pricing in the arm’s length range, and fulfilling documentation requirements. How and why to perform a transfer pricing benchmarking? We conduct the analysis by comparing the prices charged (or the results achieved) in transactions between related parties with those…
What is Local File documentation? Transfer pricing documentation is a legally required document focused on intra-group transactions. You must prepare the Local File documentation when engaging in controlled transactions with related entities. Typically, it is required when the value of such transactions exceeds the financial thresholds set by regulations within the tax year. The statutory…
The year 2024 has not introduced any major changes to transfer pricing regulations. However, related parties must still carefully comply with documentation and reporting obligations for intra-group transactions made in 2023. The process begins with identifying relationships as defined by transfer pricing regulations. The next step is determining whether the transactions qualify as controlled transactions…
Transfer Pricing: who has documentation and reporting obligations? If: you are a taxable person (subject to corporate income tax or personal income tax), and in 2023, you engaged in transactions with related parties, and the value of these transactions exceeded the statutory thresholds in 2023, then you need to determine your transfer pricing obligations…
Transfer Pricing: obligations await! The holidays are coming to an end, and as children head back to school, businesses must also turn their attention to fulfilling transfer pricing obligations for the 2023 tax year. Key deadlines are approaching for: Local transfer pricing documentation (Local File) Transfer pricing information (TPR) Group transfer pricing documentation (Master File)…
Transfer prices can impact the amount of income taxed in different countries. To ensure compliance, set these prices at the same level that unrelated parties would use in their transactions. Here’s how to do it. Various transfer pricing verification methods are used to assess the prices set between related parties. There are five basic methods,…