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Local File (application of Arm's Length Principle (comparability…
Local File
identity and business activities
management structure, organisation chart, information of associated parties
description of the business and business strategy
explanation of aspects of transactions
business environment including key competitors
information about Related Party Transaction and independent transaction
transaction sceme
Transfer pricing policies for the last 5 years
material controlled transactions and the context in which such transactions take place
The amount of intra-group payments and receipts
associated enterprises involved and the relationship amongst them
table contains information of VAT receipts, counterparts and their countries /jurisdiction, product specification and quantity, date of sending/shipment
Copies of all material intercompany agreements concluded by the local entity
financial information
Annual local entity financial accounts
Segmented financial statement
allocation schedules showing how the financial data used
Summary schedules of relevant financial data
non-financial events/occasions/facts
non-financial events/occasions/facts which determine price or profit level
application of Arm's Length Principle
comparability adjustments performed
application transfer pricing method
A summary of financial information
selected comparable
comparable search methodology and
the source of such information
reasons for performing a multi-year analysis
important assumptions
tested party, reasons for the selection.
Information on relevant financial indicators
most appropriate transfer pricing method and the reason
business characteristics
comparability and functional analysis
reasons for concluding that transfer pricing satisfies ALP
A copy of existing APAs and other tax rulings