Transfer Pricing

Tax

ARE YOU COMPLIANT WITH TRANSFER PRICING REQUIREMENT?

Tax Return and Transfer Pricing Compliance

With effect from year of assessment 2014, the income tax return for companies has a mandatory requirement to confirm the availability of transfer pricing documentation to support their related party transactions. Therefore, all taxpayers with related party transactions must prepare/update their transfer pricing documentation on an annual basis and adhere to the tax return filing deadline. The following are the potential tax implications of a “No” response on the tax return, if the taxpayer has related party transactions:

A higher possibility the taxpayer could be selected for transfer pricing audit/field audit;Exposure to higher penalty in the event of a transfer pricing audit; A “No” response could be viewed as “willful default” or ‘negligence’ - two circumstances under which the statute of limitation will be revoked.

As such, it is important to prepare transfer pricing documentation as prescribed under the Transfer Pricing Guidelines 2012 and theTransfer Pricing Rules 2012.

How we can help?

Early identification of existing issues and compliance with local regulatory requirements is important in managing transfer pricing risks.

Our integrated national and international networks of transfer pricing specialists assist taxpayers meet their specific and unique transfer pricing requirements. These experts work collaboratively with international tax teams in order to optimise the commercial and fiscal structure of multi-national groups. Our expertise covers both industry specific and transaction based transfer pricing issues.