Updated: Sep 8
RULE 4 CONTEMPORANEOUS TRANSFER PRICING DOCUMENTATION
4(1) A person who enters into a controlled transaction shall prepare a contemporaneous transfer pricing documentation.
4(2) The contemporaneous transfer pricing documentation shall include records and documents that provide a description of the following matters:
(a) organizational structure, including an organization chart covering persons involved in a controlled transaction;
(b) nature of the business or industry and market conditions;
(c) the Controlled Transaction;
(d) strategies, assumptions and information regarding factors that influenced the setting of any Pricing Policies
(e) Comparability, Functional and Risk Analysis;
(f) selection of the Transfer Pricing Method;
(g) application of the transfer pricing method;
(h) documents that provide the foundation for or otherwise support or were referred to in developing the transfer pricing analysis;
(i) index to documents; and
(j) any other information, data or document considered relevant by the person to determine an arm’s length price.
4(3) For the purpose of this rule—
"Contemporaneous Transfer Pricing Documentation" means transfer pricing documentation which is brought into existence—
(a) when a person is developing or implementing any controlled transaction; and
(b) wherein a basis period for a year of assessment the controlled transaction is reviewed and there are material changes, the documentation shall be updated prior to the due date for furnishing a return for that basis period for that year of assessment.
第4规则 - 同期转让定价文件
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