Cabinet Decision No. 39 of 2019, Article 56, requires linked entities to submit a transfer pricing statement with their annual return if they meet specific revenue or asset thresholds. The Authority can request additional information or a specialized questionnaire within 30 days to assess risks. During audits, the Authority may demand supplementary documents to verify transfer pricing practices. This proactive disclosure and the Authority's right to detailed follow-ups ensure that transfer pricing risks are monitored closely and that taxpayers maintain high standards of transparency.
SECTION 8 - TAX AVOIDANCE
Chapter 2 - Indirect Transfer of Profits between Related Entities
Article 56
A linked entity must provide the necessary information to the Authority to identify and assess its transfer pricing risks and to audit its transfer pricing practices.
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