Key takeaways:
- Scope of application and identification of related-party relationships: ownership ratios, lending relationships, control rights, and family relationships.
- Determination of related-party transaction prices: pricing methods, arm’s-length range, and principles of analysis and comparability.
- Service expenses and interest expenses: potentially non-deductible expenses and the 30% EBITDA cap on deductible interest expenses.
- Transfer pricing documentation: Local File, Master File, and Country-by-Country Report; deadlines for providing documentation upon request by tax authorities.
- Cases eligible for exemption from preparing transfer pricing documentation: conditions relating to revenue, related-party transactions, advance pricing agreements, and profit margins.
- Rights and obligations of enterprises and tax authorities: confidentiality of information, data provision obligations, and tax assessment rights where enterprises fail to meet the requirements.
