Documentation of transfer prices

Grinciples for determining transfer prices

• Arm's length principle.
• Presentation of the most important transfer pricing methods, practical examples.
• Strategic analyses, comparative data.

National legal bases for transfer pricing documentation

• Principle of official investigation, taxpayer's duty to cooperate under tax law, Profit Deferral Recording Ordinance, Function Shifting Ordinance, various administrative principles.

Principles for the preparation of transfer pricing documentation

• Scope of application, form and retention of records, person obliged to keep records, time frame, individual recording or summary of business transactions, simplifications for small companies, usability and correction options for records, content and scope of documentation (basic principles), sanctions for breaches of obligations to cooperate.

Local File

• Explanation of the requirements for factual documentation, general structure of factual documentation with practical tips, special notes on functional and risk analysis.

• Explanation of the requirements for appropriateness documentation, general structure of appropriateness documentation with practical tips, transfer pricing analysis outside of transfers of functions, transfer pricing analysis with fully comparable arm's length values, transfer pricing analysis with limited comparable arm's length values, hypothetical arm's length comparison, concept of transfer of functions, transfer pricing analysis with transfers of functions, transfer package.

Master File

• Explanation of the requirements for a master file, general structure, recording content.

Country-by-Country Report

• Explanation of the requirements for country-by-country reporting, scope of application, recording content.

Risk management in the company

• Responsibility for documentation, documentation processes within the company, internal guidelines, binding advance pricing information (APAs), legal remedies and mutual agreement procedures.