Many countries have adopted documentation-related penalties to ensure efficient operation of transfer pricing documentation requirements. They are designed to make non-compliance more costly than compliance. Penalty regimes are governed by the laws of each individual country. Country practices with regard to transfer pricing documentation-related penalties vary widely. The existence of different local country penalty regimes may influence the quality of taxpayers’ compliance so that taxpayers could be driven to favour one country over another in their compliance practices.
TPG2022 Chapter V paragraph 5.40
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By OECD
Category: OECD Transfer Pricing Guidelines (2022), TPG2022 Chapter V: Transfer Pricing Documentation | Tag: Documentation penalty, Penalty/Fine, Transfer pricing documentation
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