As explained above, transfer pricing analysis necessitates some information to be available about foreign associated enterprises, the nature and extent of which depends especially on the transfer pricing method used. However gathering such information may present a taxpayer with difficulties that it does not encounter in producing its own information. These difficulties should be taken into account in developing rules and/or procedures on documentation.
TPG2017 Chapter III paragraph 3.23
Posted on | By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Comparability analysis, Detailed information on the foreign associated, Tested party
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