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Compilation of Compliance Documentation

Action 13 released by the Organisation for Economic Co-operation and Development (OECD) in October 2015 as part of the OCED’s Base Erosion and Profit Shifting (BEPS) Action Plan, prescribes a three-tiered approach to Transfer Pricing documentation, comprising:

a Country-by-Country Report (CbC report) that provides information relevant for a high-level risk assessment in relation to each tax jurisdiction in which an MNE group operates;

A master file with information regarding a multinational enterprise’s (MNE group) global business operations and transfer pricing policies;

A local file with detailed information relating to transfer pricing transactions and policies in a specific tax jurisdiction.

We can compile your Transfer Pricing compliance documentation, using information obtained from you, such as your Annual Financial statements, website information, annual report, information obtained from functional analysis questionnaires and interviews, relevant agreements, etc.

We also offer the service of reviewing your current or prior Transfer Pricing documentation to assess your level of compliance with relevant guidance and legislation, providing recommendations to you with the intention of assisting you in minimising your risk of any Transfer Pricing adjustments by Revenue Authorities.

Unsure if you have an obligation to prepare and maintain Transfer Pricing documentation? Contact us to assist you in determining whether this obligation exists for you or not.