Enquire a detailed transfer pricing risk analysis

Contact our experts regarding a high-level transfer pricing risk analysis. Please provide us with your contact details and we will get in touch. Please feel free to ask specific questions you may already have.

TP Matrix

APAC

Australia - APAC

Yes
FY 2016
12/31/2017
FY 2016
No
Yes
21 - 28 days
Yes
Yes
Yes if local comparables not available
No
Yes
4

Enquire a Transfer Pricing Risk Analysis

China - APAC

Yes
FY 2016
Not applicable (yet)
FY 2016
Yes
Yes
30 days
Yes
Yes
Yes if local comparables not available
Yes
Yes
5

Enquire a Transfer Pricing Risk Analysis

Hong Kong - APAC

No, but consultation period runs until 31 december 2016.
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
No
No upon request
Within 30 days of request
Yes
Yes
Yes
No
Yes
2

Enquire a Transfer Pricing Risk Analysis

India - APAC

Yes for CBC, draft bills for MF & LF
FY 2016-2017
10/30/2017
FY 2016-2017
Yes
Yes
30 days
Yes
Yes
No
No
Yes
5

Enquire a Transfer Pricing Risk Analysis

Indonesia - APAC

No, but likely 2017
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
No upon request
1 month
Yes
Yes
Yes
Yes but upon approval TP documentation is also accepted in English.
Yes
4

Enquire a Transfer Pricing Risk Analysis

Japan - APAC

Yes
FY 2016
12/31/2017
MF: FY 2016 LF: FY starting on or after april 1, 2017
Yes
No upon request
Without delay. In practice, usually deadlines are specified (negotiable).
Yes
Yes
No
Yes
Yes
3

Enquire a Transfer Pricing Risk Analysis

Malaysia - APAC

Yes, effective from 1-1-2017
by 31 December 2018 for FY 2017
by 31st December for FY 2017
Refer to extensive TP Matrix
Yes
No, only upon request
30 days
Yes
Yes
No, strong preference over local comparables
No
Yes
4

Enquire a Transfer Pricing Risk Analysis

New Zealand - APAC

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
No
No
30 days
Yes
Yes
Yes if local comparables not available
No (already in English).
Yes
3

Enquire a Transfer Pricing Risk Analysis

Philippines - APAC

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
No upon request
Tax examiners usually specify deadline
Yes
Yes
Yes
No
No
3

Enquire a Transfer Pricing Risk Analysis

Singapore - APAC

Yes for CBC only
FY 2017
Not applicable (yet)
Not applicable (yet)
Yes
No upon request
Documentation should be made available if requested by the IRAS.
Yes
Yes
Yes if local comparables not available
No (already in English).
Yes
3

Enquire a Transfer Pricing Risk Analysis

South Korea - APAC

Yes but first master/local file and in a few years cbcr.
Not applicable (yet)
Not applicable (yet)
FY 2016
Yes
Yes
60 days. Can be extended up to another 60 days.
Yes
Yes
Yes if local comparables not available
Yes, but English may be accepted upon approval from the NTS.
Yes
4

Enquire a Transfer Pricing Risk Analysis

Taiwan - APAC

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
Yes
1 month
Yes
Yes
Yes if local comparables not available
Yes but upon approval TP documentation is also accepted in English
No
3

Enquire a Transfer Pricing Risk Analysis

Thailand - APAC

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
No.
In a timely manner. An extension of the submission deadline may be requested.
Yes
Yes
Yes if local comparables not available
Yes, official language is Thai. In practice, English is generally accepted.
Yes
3

Enquire a Transfer Pricing Risk Analysis

Vietnam - APAC

Yes
Requirement Effective from 1 May 2017
Not specified yet
Requirement Effective from 1 May 2017
Yes
Annual declaration, and upon request the documentation
15 days from date of request
Yes
Yes
Yes, with adjustments
Yes
Yes
4

Enquire a Transfer Pricing Risk Analysis

Europe

Austria - Europe

Yes
FY 2016
12/31/2016
FY 2016
Yes
No upon request
At short notice (documentation should be established at tax filing).
Yes
Yes
Yes. However, it is required to explain the chosen research in detail.
(parts of) the documentation may be requested in German.
Yes
4

Enquire a Transfer Pricing Risk Analysis

Belgium - Europe

Yes
FY 2016
12 months after accounting period ends
FY 2016
Yes
Yes, Local File with annual tax return and MF 12 months after year-end.
Documentation has to be filed.
Yes
Yes
Yes, pan-European comparables allowed.
(parts of) documentation may be requested in French /Dutch.
Yes
4

Enquire a Transfer Pricing Risk Analysis

Bulgaria - Europe

No
Not applicable (yet)
December 31, 2016
Not applicable (yet)
No
No upon request
Usually within 14 days which can be extended by another 14 days by request.
No
Yes
Yes, provided local comparables are not available.
Yes
Yes
3

Enquire a Transfer Pricing Risk Analysis

Czech Republic - Europe

Yes, CbCr implemented, MF and LF recomended
FY 2016
October 31, 2017 or at FYE (if later)
recommended
No, but highly recommended
Yes, on request
No binding timeframe, depends on Financial Office request
Yes
Yes
Yes if comparables are reasonable
Yes
Yes
4

Enquire a Transfer Pricing Risk Analysis

Denmark - Europe

Yes
FY 2016
December 31, 2016
Optional FY 2016
Yes
Yes a list of 33 questions, and upon request the documentation
60 days. Requests for multiple benchmarks can be extended to 90 days.
Yes
Yes
Yes, but Danish or Nordic comparables are preferred.
No
Ywa
4

Enquire a Transfer Pricing Risk Analysis

France - Europe

Yes
FY 2016
5/31/2016
FY 2016
Yes
Yes
Upon immediate request by the tax inspector on the day of an audit or 30 days.
Yes
Yes
Yes if meaningful sub-set of French comparables
English is in practice accepted. The annual TP form must be in French.
Yes
4

Enquire a Transfer Pricing Risk Analysis

Germany - Europe

Yes
FY 2016
May 31, 2017 (part of tax return)
FY 2017
Yes (in practice and formally if revenues exceed 100 million)
No upon request
60 days for regular business transactions / 30 days for extraordinary business event.
Yes
Yes
Yes, if it can be proven that market conditions in the other state(s) are comparable
Documentation must be in German, but in practice, English is often accepted.
Yes
5

Enquire a Transfer Pricing Risk Analysis

Hungary - Europe

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
No upon request
Promptly upon the tax authority's request (this means a few days).
Yes
Yes
Yes, as long as the economic conditions are substantially the same.
Generally, no (although the tax authority may require translation).
Yes
4

Enquire a Transfer Pricing Risk Analysis

Ireland - Europe

Yes
FY 2016
12/31/2016
FY 2016
Yes
No upon request
3 months. A request cannot be initiated before the tax return has been filed.
Yes
Yes.
Yes
No (already in English).
Yes
1

Enquire a Transfer Pricing Risk Analysis

Italy - Europe

Yes
FY 2016
Not applicable (yet)
Not applicable (yet)
No
No upon request
10 days. Extension of additional 7 days possible at tax authorities' discretion.
Yes
Yes
Yes if local comparables not available
Documentation for penalty protection must be in Italian. MF can be in English.
Yes
5

Enquire a Transfer Pricing Risk Analysis

Luxembourg - Europe

No, but draft legislation
FY 2016
3/31/2017
FY 2016
Yes
No upon request
Upon request as it has to be prepared when filing the tax return
Yes
Yes
Yes, pan-European comparables allowed.
No.
No
3

Enquire a Transfer Pricing Risk Analysis

Netherlands - Europe

Yes
FY 2016
September 1, 2017 or at FYE (if later)
FY 2016
Yes
No, but needs to be in administration
Readily available as it has to be in the administration.
Yes
Yes.
Yes, pan-European comparables allowed.
No.
No
4

Enquire a Transfer Pricing Risk Analysis

Poland - Europe

yes
2016 (if calendar year alike)
12 months after tax year/accounting period ends
FY2017 (if calendar year alike)
yes (above €2M of turnover or operational costs, except transactions with tax havens)
no/yes
7 days, generally
yes
yes
yes
yes
statement by the board members
5

Enquire a Transfer Pricing Risk Analysis

Portugal - Europe

Yes. CbC and signed the MCAA. (no MF/LF)
FY 2016
December 31, 2017
Common practice but not yet implemented in the local law
Yes
No upon request
10 days
Yes
Yes
Yes, but with preference for local comparable (Portuguese). If it is not possible to determine local comparable it is recommendable to progressively enlarge the screening to Spain and, only after that, to Europe and finally, if needed, to the World.
Yes
Yes
5

Enquire a Transfer Pricing Risk Analysis

Romania - Europe

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
Yes
10 days for large taxpayers, 3 months for small taxpayers
Yes
Yes
Yes if local comparables not available
Yes
No
5

Enquire a Transfer Pricing Risk Analysis

Russia - Europe

No but draft legislation.
FY 2017
Not applicable (yet)
Not applicable (yet)
Yes
No upon request, but annual TP declaration needs to be filed.
30 days
Yes
Yes
No
Yes
Yes
4

Enquire a Transfer Pricing Risk Analysis

Spain - Europe

Yes
FY 2016
12/31/2016
FY 2016
Yes
Yes
Documentation may be requested at any time after the taxpayer files the return.
Yes
Yes
Yes, if local comparables are not available
No, although a translation may be requested during a tax audit or in court.
Yes
3

Enquire a Transfer Pricing Risk Analysis

Switzerland - Europe

No but draft legislation, signed the MCAA
FY 2018
End of FY 2018 + 12 months
Not applicable
Yes, only CbCr
No specific disclosure requirement.
Not applicable (yet)
Yes
Yes
Yes
Yes
Yes
2

Enquire a Transfer Pricing Risk Analysis

Turkey - Europe

MF, LF and CbC draft regulations but not signed the MCAA.
FY 2016 (Based on the draft regulation)
Not applicable (yet)
FY 2016 (Based on the draft regulation)
Yes
No upon request, but annual TP Form needs to electronically be filed along side tax return.
15 days
Yes
Yes
Yes if local comparables not available
Yes
Taxpayers have to follow the specific LF format determined by Turkish TP legislation.
4

Enquire a Transfer Pricing Risk Analysis

UK - Europe

Yes CbCr: No for MF/LF
FY commencing in 2016
9/1/2017
MF/LF not required
Yes (in practice)
No upon request
typically, 30 days
Yes
Yes.
Yes if local comparables not available
Yes (if not in English)
Yes
4

Enquire a Transfer Pricing Risk Analysis

Middle-East

Bahrain - Middle East

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
No






No
1

Enquire a Transfer Pricing Risk Analysis

Iraq - Middle East

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
No



No
CUP preferred
Yes
Yes
1

Enquire a Transfer Pricing Risk Analysis

Israel - Middle East

Yes (draft TP Decree, expected to be effective as of 2017)
Most probably 2017
Within one year from the end of the tax year
Most probably 2017
Yes
Documentation is submitted upon request by the ITA. Tax return disclosures of all controlled transactions is required (Form 1385).
Within 60 days from the request by the ITA
Standard penalties in accordance with the ITO relevant provisions
Yes
Search for Israeli comparables is recommended. In practice, Pan European or global benchmark is acceptable, if it is proved that domestic comparables are not available.
No
The ITA place great emphasis on transfer pricing issues and attempt to implement the BEPS Actions 8-10 report principles in current tax audits
5

Enquire a Transfer Pricing Risk Analysis

Jordan - Middle East

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
No



No
CUP preferred
Yes
Yes
1

Enquire a Transfer Pricing Risk Analysis

Kuwait - Middle East

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
No



No
CUP preferred
Yes
Yes
1

Enquire a Transfer Pricing Risk Analysis

Oman - Middle East

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
No



No
CUP preferred
Yes
Yes
1

Enquire a Transfer Pricing Risk Analysis

Qatar - Middle East

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
Yes
Prior to transaction if not using CUP

Yes
No
Yes
Yes
2

Enquire a Transfer Pricing Risk Analysis

Qatar QFC - Middle East

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
No upon request


Yes
No

No
2

Enquire a Transfer Pricing Risk Analysis

Saudi Arabia - Middle East

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
No
No upon request


No

Yes
Yes
1

Enquire a Transfer Pricing Risk Analysis

United Arab Emirates - Middle East

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
No




CUP preferred

No
1

Enquire a Transfer Pricing Risk Analysis

North-America

Canada - North-America

CbC draft regulations and Signed the MCAA.
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
Yes
3 months.
Yes
Yes
Yes, as a supplement to Canadian comparables.
Yes (documentation may be in English or French)
Yes
4

Enquire a Transfer Pricing Risk Analysis

Mexico - North-America

LF, MF, CbC and Signed the MCAA.
FY 2016
Dec 31 of the year following FYE; DISIF: June 30; STR: July 15
FY 2016
Yes
Yes. Either by March, June or July, depending if DISIF or Dictamen were completed
15 days. Can be extended with an additional 10 days upon request.
Yes
Yes
Yes
Yes
Yes
4

Enquire a Transfer Pricing Risk Analysis

USA - North-America

Yes
FY starting on or after 30 june 2016
Not applicable (yet)
Not applicable (yet)
No, but advised for penalty protection
No, for penalty protection documentation must be in place when filing tax return.
30 days.
Yes
Yes
Yes
Yes
Yes
4

Enquire a Transfer Pricing Risk Analysis

South-America

Argentina - South-America

Signed the MCAA
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
8 months after year-end (TP report and the annual documentation)
Dependent on the specific form.
Yes
Yes
Yes
Yes
Yes
4

Enquire a Transfer Pricing Risk Analysis

Bolivia - South-America

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
Yes.

Yes
Yes


Yes
4

Enquire a Transfer Pricing Risk Analysis

Brazil - South-America

CbC and Signed the MCAA.
FY 2016
July 31, 2017
2016
Yes
Yes
30 days.
Yes
No
Yes, but very limited in some situations
Yes
Yes
5

Enquire a Transfer Pricing Risk Analysis

Chile - South-America

CbC and Signed the MCAA.
FY 2016
6/30/2017
Not applicable (yet)
Yes
Yes, the deadline for filing a transfer pricing disclosure form is June 30.
Instantly upon request.
Yes
Yes
Yes
Yes
No
4

Enquire a Transfer Pricing Risk Analysis

Colombia - South-America

LF, MF, CbC and Signed the MCAA.
FY 2016
12/31/2017
FY 2017
Yes
Submission deadline is usualy by mid July
Submission deadline is set by a resolution (in 2017 - July 11 to July 25)
Yes
Yes
Yes, when local comparables are not available.
Yes
Yes
4

Enquire a Transfer Pricing Risk Analysis

Costa Rica - South-America

Signed the MCAA
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
Yes. Disclosure form to be submitted by June.
Stated on the request
Yes
Yes
Yes if comparables are reasonable
Yes
No
3

Enquire a Transfer Pricing Risk Analysis

Dominican Republic - South-America

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
DIOR-form, 60 days after the deadline for the tax return of fiscal year.
Stated on the request
Yes
Yes
Yes
Yes
No
4

Enquire a Transfer Pricing Risk Analysis

Ecuador - South-America

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
Disclosure Form and TP Study to be filed, generally in June
As stated on the notification
Yes
Yes
Yes
Yes
Yes
4

Enquire a Transfer Pricing Risk Analysis

El Salvador - South-America

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
Disclosure form F982 must be submitted within the first three months that follow the fiscal year–end. (Regularly by end of March).
TP documentation immediately upon request.
Yes
Yes
Yes
Yes
Yes
4

Enquire a Transfer Pricing Risk Analysis

Guatemala - South-America

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
A transfer pricing annex of the income tax return has to be filed by March 31
20 business days from the date of request
Not established yet.
Yes
Yes
Yes
Yes
4

Enquire a Transfer Pricing Risk Analysis

Honduras - South-America

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
April 30, if FY is calendar year. For all other FYs, the Informative Transfer Pricing Return must be filed up to three months after the FY closes
Taxpayers must have all the information and analysis when filing their tax return (April).
Yes
Yes


No
4

Enquire a Transfer Pricing Risk Analysis

Nicaragua - South-America

No, but expected per 30 june 2017
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
Yes
No timeframe indicated, but information should be ready when filling the tax return.
To be determined by Nicaraguan tax authorities



No
3

Enquire a Transfer Pricing Risk Analysis

Panama - South-America

Signed the MCAA
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
Form 930 should be filed within 6 months of the close of the fiscal year
within 45 days of notification
Yes
Yes
Yes
Yes
Yes
3

Enquire a Transfer Pricing Risk Analysis

Peru - South-America

LF, MF, CbC
FY 2017
Not applicable (yet)
FY 2017
Yes
Disclosure Form and TP Study to be filed, generally in June
Available on request
Yes
Yes
Yes
Yes
Yes
4

Enquire a Transfer Pricing Risk Analysis

Uruguay - South-America

No, but there is draft legislation to implement
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
Form 3001 and the TP Study to be filed 9 months after FY ends
Available on request
Yes
Yes
Yes, when local comparables are not available.
Yes
Yes
3

Enquire a Transfer Pricing Risk Analysis

Venezuela - South-America

No
Not applicable (yet)
Not applicable (yet)
Not applicable (yet)
Yes
Form PT99 to be filed 6 months after FY ends.
Stated on audit notification, usually 5 days.
Yes
Yes
Yes
Yes
Yes
3

Enquire a Transfer Pricing Risk Analysis

Please contact our office in The Netherlands

Quantera Global Eindhoven, The Netherlands:

Eindhovenseweg 128
5582 HW Waalre
The Netherlands
+31 88 221 5800