The peer review guidelines call for a report to be submitted to the Working Party for each reviewed country. The report covers the legal basis for dealing with transfer pricing issues, any country guidelines to direct enforcement practices, approaches commonly used to address a complex transfer pricing problem, administrative arrangements for handling transfer pricing cases, case law principles, and experience with data gathering and taxpayer documentation. The report also is to describe experiences with administrative approaches to avoiding and resolving transfer pricing disputes (e.g. mutual agreement procedure, advance pricing arrangements and safe harbours) ...
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