+ Word must be in search result. - Words must not be in search result. * Word start/end on characters before/after symbol. ""Words in quotes will be searched as phrase.

 

WTS Global Country TP Guide:
A comprehensive survey on Transfer Pricing from 73 countries

12 October, 2018 Newsletters

Since the publication of the final OECD BEPS reports, there has been a wave of local implementation initiatives. In light of these developments, WTS Global prepared a study demonstrating the implementation status of OECD BEPS 13 and related practical transfer pricing questions in more than 70 countries as of the end of the year 2017.

We would like to present to you global survey on TP documentation and related practical questions following numerous local OECD BEPS Action 13 implementation initiatives.

The following transfer pricing topics have been addressed in the survey:

  • Legal TP documentation requirements and TP policies
  • OECD BEPS Action 13 requirements
  • TP disclosure and TP specific returns
  • Benchmarking
  • Year-end adjustments
  • Transfer Pricing Audit and Dispute Resolution Mechanisms

Here are some of key findings:

  • Study confirms a large-scale roll-out especially of CbCR. Various countries have already implemented the MF and LF documentation concept but to a lesser degree than CbCR. It is also apparent that several countries have tightened up rules on penalties for non-compliance. Specifically, in six countries, non-compliance with the CbCR requirements could lead to imprisonment.
  • In almost all countries a large penalty and/or imprisonment is imposed, if a taxpayer files a tax return for which he understands or should understand that the result reported in that tax return is too low, due to incorrect transfer pricing. In many countries the same applies for the advisor/accountant/administrator who drafts and files the tax return of a client and understands or should understand that the result reported is too low due to incorrect transfer pricing.
  • Local tax authorities focus on transfer pricing during tax audits, especially on the low hanging fruit such as loss making companies and intercompany charges for services. In addition an increased tax audit focus is seen on the remuneration of intellectual property and on intercompany financing. WTS Global expects an increased transfer pricing audit focus on financing, also given the discussion draft on financial transactions that has been issued by the OECD recently.

This survey will be updated on a regular basis. Updates will be available by the link.

Download pdf-file of the survey (3 Mb).

Kind regards,

© WTS Consulting LLC, 2018

Views 16964

SIMILAR POSTS

Better late than never: Legislators have finally decided to improve the rules on liability for correction of TP Reporting 12 March, 2025    1376

The Cabinet of Ministers of Ukraine has updated the list of low-tax jurisdictions 20 January, 2025    2207

The Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports has entered into force for Ukraine: Implications for participants of MNE groups in Ukraine 07 November, 2024    878

Changes in the characteristics of non-resident counterparties for recognising transactions as controlled or making a 30% adjustment for corporate profit tax purposes 02 August, 2024    2138

Ukrainian Court Denies Characterization As Stewardship Expenses 10 July, 2024    951

Comparables Selection Was Correct After All, Ukrainian Court Says 11 April, 2024    514

The case Olympex Coupe International v. State Tax Service: the Supreme Court of Ukraine has finally decided to disallow the tax office’s “creative” application of the transactional net margin method 01 March, 2024    1549

Important transfer pricing court practice: the cassation appeal of the tax office has been (partially) satisfied again by the Supreme Court – why is the case important and what significant nuances have not been taken into account? 13 November, 2023    2015

Comparables Analysis Insufficient; Ukrainian Court Remands Case 18 September, 2023    1200

“Massive” requests regarding application of the 30% adjustment on corporate income tax. What is wrong and what to do? 03 August, 2023    2865

Ukraine: The War is not an excuse to ignore Transfer Pricing Compliance 06 February, 2023    1191

Finally! Ukraine has joined Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports 09 November, 2022    1899

Comment