BEPS Action 13

TP Back to Basics – Transfer Pricing Documentation

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Introduction

Chapter 5 of the “OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations” (the “Guidelines”) provides guidance for tax authorities on developing rules for transfer pricing documentation and guidance for multinational enterprises (MNEs) on the standard of transfer pricing documentation that would be most helpful for demonstrating that their controlled transactions are conducted on an arm’s length basis.

This article is my summary of the key elements of Chapter 5. It concludes with my thoughts on best practice regarding the UK and HMRC’s TP documentation requirements.

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