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OECD releases report on transfer pricing of financial transactions
13 February 2020
The Organisation for Economic Co-operation and Development (OECD) on 11 February released final guidance on the transfer pricing aspects of financial transactions. The long-awaited release marks the first time the OECD transfer pricing guidelines (TPG) will be updated to include such guidance.
Meet Our Transfer Pricing Team
Deloitte transfer pricing professionals help multinational companies to price their intercompany transactions, such as sales of goods, the provision of services, and transfers of intangible property, and to document, support, and defend the pricing for such transactions.
Transfer Pricing Documentation Summary
Deloitte's Transfer Pricing practice has prepared the Global Tax Reset - Transfer Pricing Documentation Summary, which compiles essential country-by-country reporting and documentation information (including master file/local file information, if applicable) for 136 jurisdictions around the world.
Significant changes in the transfer pricing documentation rules
Errors in documentation may lead to large fines
Due to the regulatory changes, preparation of the transfer pricing documentation may place a bigger administrative burden on companies, so it is worth starting it as soon as possible and leave more time for this task than before.
New transfer pricing regulation – focus on profitability calculation
Transfer pricing remains a priority audit area for the tax authority. For financial years beginning on or after 1 January 2018, taxpayers are required to prepare their transfer pricing reports according to the provisions of NGM decree no. 32/2017. (X.18.) (hereinafter: “NGM decree”).
Corporate taxpayer groups: can transfer pricing requirements be overlooked?
As a general rule, although itemised transfer price adjustment and documentation regulations of the corporate tax act are not applicable for transactions between companies involved in group corporate taxation, liabilities regarding transfer pricing may still arise for them.