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By Danny BEETON, Arendt Medernach*
Transfer pricing can no longer be regarded as a difficult corporate income tax compliance requirement to be dealt with by a specialist team once a year – its concepts are being adopted in other taxes, and they need to be understood more widely across the business.
By now, larger multinational businesses will be familiar with their core transfer pricing compliance obligations, namely:
- an annual country-by-country report of local substance, profits and tax paid;
- a global master file explaining the business’s profit drivers, supply chain/s and the profit contribution of individual companies; and
- local files detailing the related party transactions of the local subsidiaries and how...
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