While Myanmar has not yet adopted transfer pricing regulations, the draft Income Tax Bill provides for comprehensive regulations to address cross-border transfer pricing in accordance with international OECD standards.
The correct pricing of transactions between related parties is a topic which is under scrutiny of tax authorities around the world, and will in future attract more attention from the Myanmar Internal Revenue Department. Applying prices that are not at arm's length can have significant impact on a company's tax liability. Proper transfer pricing documentation is the best defence if prices applied on intercompany transactions are challenged by tax authorities and therefore helps to reduce the risk of tax adjustments.
This workshop will provide an overview of how transfer pricing documentation based on the OECD Guidelines for Multinational Enterprises and Tax Administrations ("OECD Guidelines") should look like.
We will start by providing answers to the question on what transactions the arm's length principle has to be applied, followed by an overview of what transfer pricing methods are available to determine the arm's length principle. Lastly, we will provide an overview of what information proper transfer pricing documentation has to contain based on the OECD Guidelines and share our experience on best practice approaches.
More details on time and venue coming soon.
FOR MEMBERS ONLY
Getting ready for transfer pricing - documentation in practice