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Transfer Pricing Alert

Reminder to Taxpayers: Updating of Transfer Pricing Documentation

To ensure compliance with transfer pricing regulations, it is recommended that taxpayers periodically review their transfer pricing documentation (TPD). This helps confirm that functional and economic analyses remain accurate and relevant, and that the transfer pricing methodology applied is valid.

Key points

  • Annual Review: The TPD should generally be reviewed and updated annually.
  • Database Searches: Searches in databases for comparables supporting the TPD should be updated every three years, provided operating conditions remain unchanged.
  • Annual Financial Updates: Financial data for comparables should be updated annually to reliably apply the arm’s length principle.
  • Updating of TPD: If there are significant changes in the business model, the factors or conditions considered in drafting the TPD, and the nature of the related party transactions.

(Chapter V: Documentation, OECD Transfer Pricing Guidelines, January 2022 and Revenue Memorandum Circular No. 76-2020)

Staying on top of these updates helps ensure your documentation remains compliant and accurate.

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