-
1.
Identify the principal transfer pricing legislation.
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
2.
Which central government agency has primary responsibility for enforcing the transfer pricing rules?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
3.
What is the role of the OECD Transfer Pricing Guidelines?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
4.
To what types of transactions do the transfer pricing rules apply?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
5.
Do the relevant transfer pricing authorities adhere to the arm’s-length principle?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
6.
How has the OECD’s project on base erosion and profit shifting (BEPS) affected the applicable transfer pricing rules?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
7.
What transfer pricing methods are acceptable?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
8.
Are cost-sharing arrangements permitted? Describe the acceptable cost-sharing pricing methods.
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
9.
What are the rules for selecting a transfer pricing method?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
10.
Can a taxpayer make transfer pricing adjustments?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
11.
Are special ‘safe harbour’ methods available for certain types of related-party transactions? What are these methods and what types of transactions do they apply to?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
12.
Does the tax authority require taxpayers to submit transfer pricing documentation? What are the consequences for failing to submit documentation?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
13.
Other than complying with mandatory documentation requirements, describe any additional benefits of preparing transfer pricing documentation.
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
14.
When must a taxpayer prepare and submit transfer pricing documentation to comply with mandatory documentation requirements or obtain additional benefits?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
15.
What content must be included in the transfer pricing documentation? Are a separate ‘master file’ and ‘local file’ required? What are the acceptable languages for the transfer pricing documentation?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
16.
Has the tax authority proposed or adopted country-by-country reporting? What, if any, are the differences between the local rules adopting country-by-country reporting and the consensus framework of BEPS Action 13?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
17.
How long does the authority have to review a transfer pricing filing?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
18.
If the tax authority proposes a transfer pricing adjustment, what initial settlement options are available to the taxpayer?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
19.
If the tax authority asserts a final transfer pricing adjustment, what options does the taxpayer have to dispute the adjustment?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
20.
Does the country have a comprehensive income tax treaty network? Do these treaties have effective mutual agreement procedures?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
21.
How can a taxpayer request relief from double taxation under the mutual agreement procedure of a tax treaty? Are there published procedures?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
22.
When may a taxpayer request relief from double taxation?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
23.
Are there limitations on the type of relief that the competent authority will seek, both generally and in specific cases?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
24.
How effective is the competent authority in obtaining relief from double taxation?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
25.
Does the country have an advance pricing agreement (APA) programme? Are unilateral, bilateral and multilateral APAs available?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
26.
Describe the process for obtaining an APA, including a brief description of the submission requirements and any applicable user fees.
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
27.
How long does it typically take to obtain a unilateral and a bilateral APA?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
28.
How many years can an APA cover prospectively? Are rollbacks available?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
29.
What types of related-party transactions or issues can be covered by APAs?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
30.
Is the APA programme widely used?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
31.
Is the APA programme independent from the tax authority’s examination function? Is it independent from the competent authority staff that handle other double tax cases?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
32.
What are the key advantages and disadvantages to obtaining an APA with the tax authority?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
33.
Is the tax authority generally required to respect the form of related-party transactions as actually structured? In what circumstances can the tax authority disregard or recharacterise related-party transactions?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
34.
What are some of the important factors that the tax authority takes into account in selecting and evaluating comparables? In particular, does the tax authority require the use of country-specific comparable companies, or are comparables from several jurisdictions acceptable?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
35.
What is the tax authority’s position and practice with respect to secret comparables? If secret comparables are ever used, what procedures are in place to allow a taxpayer to defend its own transfer pricing position against the tax authority’s position based on secret comparables?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
36.
Are secondary transfer pricing adjustments required? What form do they take and what are their tax consequences? Are procedures available to obtain relief from the adverse tax consequences of certain secondary adjustments?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
37.
Are any categories of intercompany payments non-deductible?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
38.
How are location savings and other location-specific attributes treated under the applicable transfer pricing rules? How are they treated by the tax authority in practice (if different)?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
39.
How are profits attributed to a branch or permanent establishment (PE)? Does the tax authority treat the branch or PE as a functionally separate enterprise and apply arm’s-length principles? If not, what other approach is applied?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
40.
Are any exit charges imposed on restructurings? How are they determined?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
41.
Are temporary special tax exemptions or rate reductions provided through government bodies such as local industrial development boards?
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
Updates and trends
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us.
or take a tour
Albania
Australia
Austria
China
Ecuador
Germany
Greece
India
Indonesia
Ireland
Italy
Japan
Mexico
Turkey
United Kingdom
United StatesFollow Getting the Deal Through for the latest updates on law and regulation worldwide
Follow us on LinkedInGTDT: Market Intelligence provides a unique perspective on evolving legal and regulatory landscapes in major jurisdictions around the world. Through engaging, easily comparable interviews, the series provides the legal profession's thought leaders with a platform for sharing their views on current market conditions and developments in the law.
Market Intelligence offers readers a highly accessible take on the crucial issues of the day and an opportunity to discover more about the people behind the most interesting cases and deals.
View profile
Trench, Rossi e Watanabe is composed of highly qualified teams specialised in banking and finance law, prepared to advise local and international clients, helping them to anticipate, manage and resolve challenges created mainly by the current economic scenario and the complex Brazilian legal environment.
View more information about Trench, Rossi e Watanabe Advogados
Testimonials
We have received instruction from foreign counsel recently who found us through the publication
The comprehensive range of guides produced by GTDT provides practitioners with an extremely useful resource when seeking an overview of key areas of law and policy in practice areas or jurisdictions which they may otherwise be unfamiliar with.
My experience with GTDT Online so far has been wonderful. It is so useful when dealing with multijurisdictional legal matters. Two thumbs up for such a great tool and my congratulations to all of you for making my life easier.
Such a database is a fantastic tool to get access to the "basics" of many legal areas, almost everywhere. I do believe that GTDT has a real future and, according to me, it's one of the best legal database I've ever had access to in these last 10 years.
Briefing Signup
Sent approximately once a month, the free GTDT Briefing service alerts you of the latest titles to be published on GTDT Online.
Sign up to be notified of new content
SubscribeFollow Getting the Deal Through for the latest updates on law and regulation worldwide
Follow us on LinkedIn