WTS Global Transfer Pricing Country Guide

Since the publication of the final OECD BEPS reports, there has been a wave of local implementation initiatives. In light of these developments, WTS Global prepared a study demonstrating the implementation status of OECD BEPS 13 and related practical transfer pricing questions in 73 countries as of the end of the year 2017.

The following transfer pricing topics have been addressed in the survey:

  • Legal TP documentation requirements and TP policies
  • OECD BEPS Action 13 requirements
  • TP disclosure and TP specific returns
  • Benchmarking
  • Year-end adjustments
  • Transfer Pricing Audit and Dispute Resolution Mechanisms

The study confirms a large-scale roll-out especially of CbCR. Various countries have already implemented the MF and LF documentation concept but to a lesser degree than CbCR. It is also apparent that several countries have tightened up rules on penalties for non-compliance. Specifically, in six countries, non-compliance with the CbCR requirements could lead to imprisonment.

In almost all countries a large penalty and/or imprisonment is imposed, if a taxpayer files a tax return for which he understands or should understand that the result reported in that tax return is too low, due to incorrect transfer pricing. In many countries the same applies for the advisor/accountant/administrator who drafts and files the tax return of a client and understands or should understand that the result reported is too low due to incorrect transfer pricing.

Local tax authorities focus on transfer pricing during tax audits, especially on the low hanging fruit such as loss-making companies and intercompany charges for services. In addition, an increased tax audit focus is seen on the remuneration of intellectual property and on intercompany financing. WTS Global expects an increased transfer pricing audit focus on financing, also given the discussion draft on financial transactions that has been issued by the OECD recently.

You can download WTS Global Transfer Pricing Country Guide 2018 in PDF format here:
WTS Global Transfer Pricing Country Guide (PDF)

It is envisaged that the survey will be updated on a regular basis. Updates will be available on the website of WTS Global where you also find the specific country guides ready for download. Should you have any questions on transfer pricing or tax issues, please feel free to contact one of the colleagues in the relevant countries included in the publication. We will be happy to assist you..


Global Transfer Pricing Survey and Country Guide 2013 (PDF)