Centre for Tax Policy and Administration

Practical toolkit to support the successful implementation by developing countries of effective transfer pricing documentation requirements (Draft version)


Cover: PCT Toolkit TP Documentation

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The Platform for Collaboration on Tax – a joint initiative of the IMF, OECD, UN and World Bank Group – has undertaken, at the request of the G20, the development of a series of "Toolkits" to help guide developing countries in the implementation of policy options for issues in international taxation of greatest relevance to these countries.

This draft toolkit is intended to provide an analysis of policy options and a "source book" of guidance and examples to assist low capacity countries in implementing efficient and effective transfer pricing documentation regimes. Key points from these sources are reproduced, for ease of reference.

This first part of the Toolkit provides information on the background, context and objectives of transfer pricing documentation regimes. Part II then discusses a number of general policy options and legislative approaches relevant to all types of documentation requirements.

Part III focuses more specifically at each kind of documentation in turn, and examines the specific policy choices that are relevant to each, as well as providing a number of examples of country practices. This format inevitably involves some repetition, however a reader interested in implementing a particular type of documentation requirement can find all of the relevant information in a single section.

The final part sets out a number of conclusions.




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