Transfer Pricing

Transfer Pricing

Posts 1-5 of 5
  • Sebastian Pawlita
    Sebastian Pawlita    Premium Member
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    Sample documentation
    Hi,

    Could anybody tell me where I can find a sample of a transfer pricing documentation according to sec. 90 para 3 German Tax Procedure Act (AO)?

    Thanks in advance,

    Sebastian
    • 18 Sep 2009, 4:08 pm
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  • Dr. Eduardo de Proft Cardoso
    Dr. Eduardo de Proft Cardoso    Group moderator
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    Re^3: Sample documentation
    Dear Sirs,

    For those who are searching for similar issues, i suggest to take a look at the International Chamber of Commerce Transfer Pricing documentation model approach, you could find it here:

    http://www.iccwbo.org/uploadedFiles/ICC/policy/taxation/Stat...

    and obviously if your main target is in Europe, you´ll find usefull information (where to start) at the "code of conduct on transfer pricing documentation for associated enterprises in the European Union" (EU TPD), a common agreement ratified by all member states through Council Resolution. There you´ll find the master file basis and what should contain, as a minimum, the country-specific documentation.

    direct link for the EU official journal:
    http://eur-lex.europa.eu/LexUriServ/site/en/oj/2006/c_176/c_...

    best regards,
    Eduardo
    • 04 Oct 2009, 9:44 pm
  • Hans W. Waldvogel
    Hans W. Waldvogel    Premium Member   Group moderator
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    Re^4: Sample documentation
    Dear members,

    I agree and many thanks for this helpful links!

    Kind regards,
    HWW
    • 06 Oct 2009, 08:24 am