Documentation

GTP Dr. Markus Brem“Transfer pricing documentation” is the trigger for most transfer pricing projects in corporate groups. Documentation requirements or requests for interaction with tax authorities, as determined by national tax provisions, are binding related parties and their stakeholders to address tax compliance issues. Transfer pricing without documentation unnecessarily results in tax risk, income adjustment, or procedural sanctions.

The “Transfer Pricing Documentation” refers to the description of fact pattern, the assessment of the arm’s length nature of transactions and income allocation, and the integration of arm’s length information. Also, the tax law burdens the taxpayer to show evidence on compliance with tax law. The GTP® MANAGER is based on the definitions of the OECD BEPS Action Plans.

The transfer pricing manager uses features and content to draft the Master File, the Local File, and the CbC-Reports – standardized, quickly, reproducible. With the IT features setup, checks and reports on Compliance Management can be delivered such as on the completeness of the documentation package or on tax risk issues.

Basically, the “Documentation” is a by-product of the transfer pricing management approach of the GTP® MANAGER.