The Evolution Of Transfer Pricing Documentation

Introduction

Increasingly, transfer pricing documentation is an important focus area for both taxpayers and tax authorities. Over the past decade, tax authorities in the Asia Pacific region have strengthened their transfer pricing documentation requirements in tandem with the introduction of transfer pricing regulations (be it formal legislation or guidelines) in their jurisdictions as shown in the table below. Several tax authorities in countries such as Singapore, Malaysia and Australia have also, in recent years, stipulated the preparation of transfer pricing documentation on an annual basis.