Questions to assess your readiness to satisfy the requirements of three tiered TP documentation applicable from 1 January 2019

TP documentation requirements change significantly from 1 January 2019. We have summarized the changes below and also drafted a series of questions to help you assess the relevance of the changes for your company. 

The Law on Transfer Pricing ("TP Law") published in December 2017 introduced new requirements for multinational enterprise groups ("MNE Group(s)") with regard to the preparation of transfer pricing ("TP") documentation. The new regulation introduces the requirement to prepare three-tiered TP documentation following the recommendations in the Organization of Economic Cooperation and Development's ("OECD") Base Erosion and Profit Shifting ("BEPS") Action 13.