Discussion Draft on transfer pricing documentation

12. 3. 2014
OECD has released for comment the draft on changes in transfer pricing documentation rules and reporting obligation of companies. The draft proposes, among others, the establishment of a compulsory documentation, the so- called „Country by Country Reporting“, that could provide more detailed overview of the group tax position. Required information in the transfer pricing documentation may include the information on profit before tax or received and paid interest. The approval of the revised form of documentation is not expected until early 2015 and the implementation into Czech legislation may occur even later. It is also not clear which criteria will be set by Czech tax administration and what sanctions will be threatened in the event of non-issuance of the compulsory documentation. For more information see http://www.oecd.org/ctp/transfer-pricing/white-paper-transfer-pricing-documentation.pdf.

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