Lost in Transfer Pricing: The Pitfalls of EU Transfer Pricing Documentation
- A.K. Guðmundsson
- International Transfer Pricing Journal, 2009 (Volume 16), No 1
- 1 January 2009
This article addresses the issue of transfer pricing documentation within the European Union; the documentation rules of a number of Member States are analysed, as well as how these rules conform to the EU Transfer Pricing Documentation framework. The issues that arise from having divergent documentation rules are also considered, along with the effects that the various means of implementation have had so far and might have in the future, and the benefits of the EU TPD from the perspective of both taxpayers and tax authorities. Finally, the author suggests possible solutions that may contribute to a more harmonized means of implementing, as well as interpreting, transfer pricing documentation rules within the internal market.