Overview of Regulatory Requirements

Taxpayers engaged in related party transactions under this Decree shall be held responsible for declaring information about their related party relationships and transactions by using the Form No. 01 given in Appendix I, II and III to this Decree, and submitting their completed forms together with the corporate income tax finalization returns.

Taxpayers shall be responsible for retaining and providing the transfer pricing files comprising information, documents, data and records, including:

• Information on related related party relationships and transactions provided in the form given in Appendix I;
• Local files, including information about transfer pricing, transfer pricing policies and methods, prepared and deposited at taxpayers’ offices according to the directory of information and documents prescribed in Appendix II;
• Master files containing information about business activities of multinational groups, transfer pricing policies and methods of global groups and policies on allocation of income and decentralization of operations and functions in value chains of groups according to the directory of information and documents prescribed in Appendix III.

Taxpayers shall be responsible for providing, in a sufficient and accurate manner, and bearing legal responsibility for, information and documents included in the transfer pricing files at the requests of tax authorities during the pre-inspection or pre-audit consultation procedures. The time limit for submission of the transfer pricing file shall not be longer than 30 working days from the date of receipt of the tax authority’s request. In case where sound reasons are provided by taxpayers, the submission deadline or time limit shall be extended only once to no longer than 15 working days as from the expiry date.

Our Scope of Work

Phase 1 – Declare the related-party transactions

Given Company shall be required to declare the related-party transactions in a prescribed form, we envisage that our scope of work under “Phase 1 – Declare the related-party transactions” will be as follows:

• Declare information on related related party relationships and transactions provided in the form given in Appendix I;
• Declare local files prescribed in Appendix II

Phase 2 – Transfer pricing documentation

Taxpayers shall be responsible for retaining and providing the transfer pricing files. We envisage that our scope of work under “Phase 2 – Transfer pricing documentation” will be as follows:

• Assist Company to gather information and complete transfer pricing documentation for those related party transactions done between Company and its related parties;
• Select methods for determination of transfer pricing;
• Preparing local files, including information about transfer pricing, transfer pricing policies and methods of Company according to the directory of information and documents prescribed in Appendix II.