Statement on the preparation of documentation

The obligation to file a statement on the preparation of local transfer pricing documentation applies to related parties required to hold local transfer pricing documentation.

By the end of the ninth month following the close of the tax year, the taxpayer is required to file a statement on the preparation of the local transfer pricing documentation, declaring that:

• it has prepared the local transfer pricing documentation,
• the transfer prices of the controlled transactions covered by the local transfer pricing documentation have been set at arm's length.

The statement must be signed by the head of the entity; where several persons meet the criteria for being the head of the entity, or where it is not possible to determine who the head of the entity is, the statement is signed by each of the persons authorised to represent it. The statement may not be filed by a proxy.

The statement on the preparation of the local transfer pricing documentation is filed by electronic means of communication.