Transfer Pricing Documentation definition

Transfer Pricing Documentation means any return, declaration, statement, report, claim, schedule, form or other documentation and any associated workpapers required for purposes of establishing any position with respect to transfer pricing purposes with any Taxing Authority (including documentation described in Section 6662(e) of the Code or the Organisation for Economic Co-operation and Development transfer pricing guidelines), as determined based on the past practice of the applicable member of the J&J Group or the Kenvue Group.
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Transfer Pricing Documentation. For all transactions entered into by the Corporation with any non-resident Person with which the Corporation was not dealing at Arm's Length during a taxation year commencing after 1997 and ending on or before the Closing Date, the Corporation has made or obtained records or documents that meet the requirements of paragraphs 247(4)(a) to (c) of the Tax Act.
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Examples of Transfer Pricing Documentation in a sentence

  • Exempt arrangements and transactions [Transfer Pricing Documentation] 46 69.

  • Reviewers should be aware that CCAs are already governed by the Code of Conduct on EU Transfer Pricing Documentation (EU TPD) wherein it is stated that MNEs should include in the masterfile a list of CCAs as far as group members in the EU are affected.

  • The EU Code of Conduct on Transfer Pricing Documentation for Associated Enterprises in the European Union, agreed by the Council of the EU in June 2006, consisted of a common master file relevant to all EU group members of a multinational enterprise (and had to be provided to all relevant EU member states), as well as standardised country-specific documentation.

  • Where a Multinational Enterprise uses the EU Transfer Pricing Documentation (EUTPD), this will serve as a useful basis for any APA application.

  • Please do not hesitate to contact our tax team or your regular contact at dhpg if you need assistance with the preparation of your Transfer Pricing Documentation or if you have any other questions.

  • The importance and magnitude of prepar- ing proper Transfer Pricing Documentation is frequently underestimated by small to medium-sized group companies.

  • International Tax and Public Finance 22 (3): 426-51 Figure 1: Timeline of Effective Transfer Pricing Documentation Rules by number of countries 1994–2014 1008060402001994-1997 1998-2000 2001-2002 2003-2004 2005-2007 2007-2011 2011-2014Source: World Bank (2016), based on Oosterhoff, 2008 and PwC, 2014.

  • Whenever relevant include sources for data and analysis presented, such as SOFI, SOFA, SOFIA, SOFO, etc] Launched in February 2019 by the FAO, the State of the World’s Biodiversity for Food and Agriculture reports that biodiversity for food and agriculture is declining.

  • In order to avoid the shift of the burden of proof, the resident company needs to prepare formal Transfer Pricing Documentation in accordance with Germany's comprehensive legislation.

  • Group companies with cross-border business relations to other group companies, per- manent establishments or other affiliated entities (i.e. controlling relationship or identity of interests) are required by German tax law to prepare Transfer Pricing Documentation for all intercompany transactions.

Related to Transfer Pricing Documentation

  • Acquisition Documentation collectively, the Acquisition Agreement and all schedules, exhibits and annexes thereto and all side letters and agreements affecting the terms thereof or entered into in connection therewith.

  • Supporting Documentation means the documents listed in Schedule A of this Certificate which forms part of this

  • Design Documentation means all schematics and test, assembly and package documentation relating to the Product, including all design, specification and assembly documentation and data files for Materials, which is necessary for the production, manufacture, qualification, testing and delivery of the Product to be attached as Exhibit A.

  • Program Documentation refers to the user manuals, help windows, readme files for the Services and any Oracle Software. You may access the documentation online at xxxx://xxxxxx.xxx/contracts or such other address specified by Oracle.

  • Related Documentation means, with respect to Software, all materials, documentation (including control documentation utilized in connection with an audit), specifications, technical manuals, user manuals, flow diagrams, file descriptions and other written information that describes the function and use of such Software, but excluding source code.

  • Product Documentation means the specific materials listed under “Documentation” at xxx.xxxxxx.xxx/xxxxx, as updated by Vocera from time to time.

  • Technical Documentation means designs, reports, photographs, drawings, plans, specifications, computer software, surveys, calculations and other data, information and material collected, computed, drawn or produced, including computer print-outs.

  • User Documentation means explanatory and informational materials concerning the Company products, in printed or electronic format, which the Company or any Subsidiary has released for distribution to end users with such Company products, which may include manuals, descriptions, user and/or installation instructions, diagrams, printouts, listings, flow-charts and training materials, contained on visual media such as paper or photographic film, or on other physical storage media in machine readable form.

  • Service documentation means all records and information on one or more documents, including documents that may be created or maintained in electronic software programs, created and maintained contemporaneously with the delivery of services, and kept in a manner as to fully disclose the nature and extent of services delivered that shall include the items delineated in paragraph (E) of this rule to validate payment for medicaid services.

  • Definitive Documentation means the definitive documents and agreements governing the Restructuring Transactions as set forth in the Restructuring Support Agreement.

  • Regulatory Documentation means, with respect to the Compounds, all submissions to Regulatory Authorities in connection with the development of such Compounds, including all INDs and amendments thereto, NDAs and amendments thereto, drug master files, correspondence with regulatory agencies, periodic safety update reports, adverse event files, complaint files, inspection reports and manufacturing records, in each case together with all supporting documents (including documents that include Clinical Data).

  • Software Documentation means software information, being technical information used, or useful in, or relating to the design, development, use or maintenance of any version of a software programme.

  • Junior Financing Documentation means any documentation governing any Junior Financing.

  • Account Documentation means any and all Account information, credit applications, Cardholder Agreements and change in terms notices, Charge Transaction Data, charge slips, credit slips, payments, credit information and documents or forms of any type and in any media relating to the Program, excluding materials used for advertising or solicitations.

  • Related Party Agreement means any agreement, arrangement, or understanding between the Company and any Stockholder or any Affiliate of a Stockholder or any Director, officer, or employee of the Company, as such agreement may be amended, modified, supplemented, or restated in accordance with the terms of this Agreement.

  • Operating Documents are, for any Person, such Person’s formation documents, as certified by the Secretary of State (or equivalent agency) of such Person’s jurisdiction of organization on a date that is no earlier than thirty (30) days prior to the Effective Date, and, (a) if such Person is a corporation, its bylaws in current form, (b) if such Person is a limited liability company, its limited liability company agreement (or similar agreement), and (c) if such Person is a partnership, its partnership agreement (or similar agreement), each of the foregoing with all current amendments or modifications thereto.

  • Security Documentation means the Security Documentation applicable to the specific Services purchased by Client, as updated from time to time, and as made reasonably available by Securiti.

  • ISM Code Documentation means, in relation to a Vessel, the document of compliance (DOC) and safety management certificate (SMC) issued by a Classification Society pursuant to the ISM Code in relation to that Vessel within the periods specified by the ISM Code;

  • Ordering Document or "order" means a document that is expressly governed by the terms and conditions of this Agreement by which, when accepted by Oracle, You order Services from Oracle.

  • Flood Documentation means, with respect to each Mortgaged Property located in the United States of America or any territory thereof, (i) a completed “life-of-loan” Federal Emergency Management Agency standard flood hazard determination (to the extent a Mortgaged Property is located in a Special Flood Hazard Area, together with a notice about Special Flood Hazard Area status and flood disaster assistance duly executed by the Borrower and the applicable Loan Party relating thereto) and (ii) a copy of, or a certificate as to coverage under, and a declaration page relating to, the insurance policies required by Section 5.02(c) hereof and the applicable provisions of the Security Documents, each of which shall (A) be endorsed or otherwise amended to include a “standard” or “New York” lender’s loss payable or mortgagee endorsement (as applicable), (B) name the Collateral Agent, on behalf of the Secured Parties, as additional insured and loss payee/mortgagee, (C) identify the address of each property located in a Special Flood Hazard Area, the applicable flood zone designation and the flood insurance coverage and deductible relating thereto and (D) be otherwise in form and substance reasonably satisfactory to the Collateral Agent.