2017年-德勤全球_Global_Tax_Reset_-_Transfer_Pricing_Documentation_Summary_10页_1mb

Deloitte Global Tax Reset Transfer Pricing Documentation Summary

Core Content Overview

This document provides a summary of transfer pricing documentation requirements for 68 jurisdictions under the Global Tax Reset initiative, focusing on Country-by-Country (CbC) reporting, Master File (MF), and Local File (LF) documentation. It is based on Deloitte's understanding as of March 27, 2018, and should not be used for business decisions without consulting a transfer pricing specialist.

Key Definitions

• Secondary filing: A local filing obligation for resident entities in an MNE group when the CbC report is not received via automatic exchange.
• Local file: Either an OECD local file or documentation prepared under local regulations.
• Substantially complies: The tax authority will accept a report meeting OECD content guidelines, though additional information may be required during an audit.
• Submit: Requirement to submit all or part of the documentation.
• Provides: Requirement to provide documentation upon request.
• Contemporaneous: Documentation must be prepared by a certain date, typically the time of filing annual tax returns.
• Parent surrogate filing: Voluntary filing by Ultimate Parent Entities (UPEs) in jurisdictions that do not yet require it.

Summary of Key Jurisdictions

CbC Report

Master File (MF)

Local File (LF)/Documentation

MF & LF/Documentation Compliance

Main Points

• The CbC report is required in most jurisdictions, with due dates typically 12 months after the end of the reporting period.
• Secondary filing is required in some jurisdictions if the report is not received via automatic exchange.
• Parent surrogate filing is available in many countries, allowing UPEs to file voluntarily.
• The MF and LF are essential for transfer pricing compliance, and the OECD guidelines are often used as a basis.
• Some countries require contemporaneous documentation, while others have submission requirements.
• Penalties are generally in place, though some jurisdictions have not yet implemented them.
• Compliance with OECD MF and LF is often substantial, but may require additional information for full compliance.
• Language requirements and specific transaction rules (e.g., cost sharing, financing) are not considered in this summary.