Standing up to scrutiny: Balancing the risks and rewards in transfer pricing documentation
Companies are facing a proliferation of transfer pricing documentation demands. While the new requirements set out in the OECD’s Base Erosion Profit Shifting (BEPS) Action Plan will raise the bar still further, they could also provide the catalyst for the development of a more sustainable approach.
This article looks at the key considerations for documentation policies as companies look at how to balance the need to meet tax authority expectations with curbing cost and complexity.
Plan, implement, defend
While there is no one size fits all solution, we believe that a ‘plan, implement and defend’ approach that builds documentation into the wider risk management of tax and transfer pricing should enable companies to keep tax authorities on side without over-burdening the business.
Building documentation into a proactive and systematic approach to transfer pricing will help to minimise the potential for disputes, while curbing any unnecessary demands on your business.