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Transfer pricing documentation requirements tracker

Based on the amendments to the law “On taxes and duties” in relation to the legal requirements for transfer pricing documentation, Deloitte has prepared a Transfer Pricing Documentation Requirements tracker.

The new transfer pricing requirements are synchronized with activities carried out by the Organization for Economic Co-operation and Development (OECD), and the updated transfer pricing guidelines for taxpayers and tax administrations. The requirements are applicable to related party transactions carried out in the financial year starting on or after 1 January 2018. Furthermore, in the context of the corporate income tax (CIT) reform, related party transactions are becoming increasingly important, and receive additional scrutiny from the tax authority.