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1. What is transfer pricing? What are the advantages to a commercial entity/ group of entities of transfer pricing?
2. Why does transfer pricing need to be monitored and controlled?
3. What concepts and principles underlie the control of transfer pricing?
4. Which national/international laws or guidelines govern the control of cross-border transfer pricing? Please outline the framework of governing rules/guidelines.
5. Are group transactions within a single national jurisdiction (as opposed to cross-border transactions) subject to any controls? If so, please outline the framework of governing rules/guidelines.
6. Do transfer pricing controls apply to transactions between branches of a single legal entity?
7. What, if any, are the main criticisms of the current approach to transfer pricing? What risks may arise from transfer pricing?
8. What are permanent establishment issues and how may they arise?
9. What type of transactions may be utilised to effect transfer pricing?
10. Who can benefit from transfer pricing?
11. What legal requirements apply to a transfer pricing transaction? Please explain in outline the “arm’s length” and comparability principles. What difficulties may arise in applying the arm’s length benchmark?
12. Which methodologies may be used in applying the arm’s length principle to transfer pricing transactions, referring in particular to transfers of transfers of intangible property; comparable profits method; profit split method; cost sharing; others
13. Is it necessary to document compliance with the arm’s length principle?
14. If so, what type of documentation must be created/retained? Are there any guidelines or other sources of advice on this question?
15. What are the sanctions for failure to document compliance?
16. What documents or information must be lodged with annual tax returns? Is there a standard form which must be used?
17. Do different documentary requirements apply to small companies?
18. Which authority is empowered to review transactions to determine compliance with the arm’s length principle?
19. What factors may lead the relevant authority to conduct such a review?
20. What procedure is followed during such a review?
21. Is it possible to obtain advance approval of a transfer pricing transaction?
22. What sanctions apply if it is determined that the arm’s length principle has not been complied with?
23. Which corporate personnel/representatives need to be involved in the establishment and maintenance of transfer pricing and the associated documentation?
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