Shiv Mahalingham (Duff & Phelps) answers a query on the feasibility of taking a holistic approach to documentation for transfer pricing compliance.
Question
The master file and local file approach was supposed to bring some consistency to transfer pricing compliance and documentation; however I am finding that there are still local requirements that need to be adhered to. Is a holistic approach to documentation still possible or must we continue to reinvent the wheel in each location that departs from the OECD guidance?
Answer
Yes a global approach is possible but this has been a source of frustration for many businesses. It is important to recognise that transfer pricing regimes fall into the following categories:
those in which a master file and standard local...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Shiv Mahalingham (Duff & Phelps) answers a query on the feasibility of taking a holistic approach to documentation for transfer pricing compliance.
Question
The master file and local file approach was supposed to bring some consistency to transfer pricing compliance and documentation; however I am finding that there are still local requirements that need to be adhered to. Is a holistic approach to documentation still possible or must we continue to reinvent the wheel in each location that departs from the OECD guidance?
Answer
Yes a global approach is possible but this has been a source of frustration for many businesses. It is important to recognise that transfer pricing regimes fall into the following categories:
those in which a master file and standard local...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
