Turkey: DRAFT Communique for Transfer Pricing Documentation

April 2020: Turkey Draft Communique issued for public comment. The Draft Communique provides detailed information related to  Transfer Pricing Documentation Requirements. The outline is based on the three tier system recommended under OECD's BEPS Project Action Item 13, covering requirements for a Master File, Local File and Country-by-Country Reporting. The Local File is similar to [...]

By |2020-04-22T16:19:17+00:00April 22nd, 2020|Documentation, Europe|0 Comments

Denmark: Draft Bill Introduces Submission of Transfer Pricing Documentation

Denmark: Timely preparation of documentation not enough     A draft bill was announced in mid-September 2019 by the Danish Ministry of Taxation that would require the submission of transfer pricing documentation with taxpayers' annual tax returns, for tax years beginning on or after 1 January 2020. Under the provisions of the draft bill, if [...]

By |2019-09-27T08:49:15+00:00September 27th, 2019|Documentation, Europe|0 Comments

One way to mitigate risks associated with key transfer pricing personnel leaving the company (and taking their knowledge of the issues with them)

Tax audits can be difficult enough without facing a situation where the tax team that was in place at the time the tax returns were prepared have since moved on. We had a client reach out to us this week who is in the beginning stages of a tax audit of the group's Italian operations. [...]

By |2019-04-30T20:32:33+00:00April 30th, 2019|Audits, Documentation|0 Comments

Luxembourg Cases Highlights Documentation Importance

Luxembourg: Recent cases highlights the importance of timely and complete transfer pricing documentation to support intercompany pricing arrangements. Source: Luxembourg Times; Alessandra Cea, Transfer Pricing Senior Manager PwC Luxembourg; Marc Rasch, Transfer Pricing Partner PwC Luxembourg In case law n °, 40348 (22 October 2018), a Luxembourg entity received a shareholder loan bearing an interest rate of [...]

By |2019-04-24T07:48:04+00:00April 24th, 2019|Documentation, Europe|0 Comments