TP documentation prior to BEPSPrior to the introduction of the 2017 edition of the Guidelines, there was little specific guidance on the content of a TP documentation package. Insufficient information also meant that tax authorities were unable to conduct a transfer pricing risk assessment or quickly obtain information required for an audit enquiry. TP documentation in the BEPS eraThe three-tiered approach introduced a standardized approach to transfer pricing documentation. That is, TP documentation should clearly articulate taxpayers’ transfer pricing policy and give the tax authority assurance the group has carefully considered its TP position. He is a regular writer and public speaker on tax and transfer pricing matters.

Source: The Guardian April 20, 2018 01:41 UTC