Internal Transfer Pricing Documentation Requirement on Curaรงao As of January 1, 2017, the conditions agreed between affiliated parties with respect to intercompany transactions must be documented and properly accounted for. This includes the transfer prices charged, the transfer pricing method and the substantiation thereof.
Affiliated parties
In principle, affiliated parties are involved when the entities belong to the same group. Nevertheless, an affiliated transaction also concerns transactions between entities that do not belong to the same group, but in which the same person directly or indirectly participates in the management or supervision of, or in the capital of, both entities.
TEXT BY REJAUNA I.S. ROJER MSC, TAX CONSULTANT AT MEIJBURG & CO, CARIBBEAN
Until recently, Curaรงao did not have a statutory documentation requirement for transfer prices. This situation changed with effect from January 1, 2017. The documentation requirement concerns both affiliated transactions effected as of January 1, 2017 and contracts concluded before January 1, 2017. For transactions entered into as of January 1, 2017, the documentation must be available at the time of the transaction.
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CURAร AO BUSINESS
| NUMBER 3 | 2017
Global trends
Most countries base their rules on internal transfer pricing on the transfer pricing guidelines prepared by the OECD. These guidelines and rules on transfer pricing are being steadily tightened to counter tax evasion and profit shifting in international transactions. The tightening has led to changes in the actual application and assessment of existing tax rules and the implementation of new tax rules worldwide.
