Transfer Pricing Documentation for Permanent Establishments

The author outlines new challenges for the tax departments of multinational enterprises (MNEs) arising from the obligations under the newly revised OECD Guidelines. In the current framework of increasing scrutiny by tax authorities, such challenges are especially relevant in the case that an MNE’s presence in a given country is limited to a permanent establishment. The evolution towards the currently applicable law on transfer pricing documentation for permanent establishments and the level of implementation of the new provisions in a sample of significant countries are also presented.