Description
This article provides the content and reports of the transfer pricing documentation of a related party as necessary to comply with documentation provisions.
The package is construed on the basis of the OECD BEPS Action Plan 13 and can be tailored to the specific country.
The package contains folder structure and the reports and illustrations on the transfer pricing fact pattern.
The article is the customized report on transfer pricing documentation for the given entity including the Master File, Local File, Arm’s Length File, and Benchmarks.
The articles of the GTP® MALL provide for standardized data, structures, analysis results, and templates (hereinafter called “Deliverables”). With means of further processing, customizing, modifying, such deliverables can be deployed by the transfer pricing manager of multinational groups, regardless of inhouse experts or external experts.
Such standardized deliverables shall not be deemed tax consulting services, legal services, or audit services in the meaning of the professional legal code of the respective country.
Deliverables of the online shop (GTP® MALL) will have to be customized and added with case-specific data – in particular in the case of document templates. In particular, contract templates are of a generalized nature. The customer and its users of such deliverables are requested to individualize the template on a case-by-case basis. Neither any factual nor any legal assessment of the individual case is the content and deliverable of the products delivered by using the GTP® MALL.
We strongly recommend the customers and user of the deliverables to involve an authorized tax consultant, legal advisor, and/or auditor (public certified accountant) to review the deliverables of the GTP® MALL and to consent as to whether the articles of the GTP® MALL might have a legal or tax impact.