Transfer Pricing Documentation

Obligation to Prepare Transfer Pricing (TP) Documentation

Certain companies that engage in transactions with controlled or controlling parties (“controlled transactions”) must prepare written documentation sufficient to form the basis for assessing whether prices and terms for controlled transactions have been determined in accordance with the arm’s length principle (i.e., what could have been achieved if the transactions had been concluded between independent parties).

New Transfer Pricing Rules Effective From FY2025 and Onwards

New, more lenient TP rules were adopted during the summer, effective from FY2025. The new rules introduce increased thresholds for when companies are subject to mandatory submission of TP documentation, as well as a new minimum threshold.

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