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Transfer pricing concerns the setting of prices and terms and conditions for the trade that takes place between two or more parties in the same corporate group (so-called "controlled transactions"). Companies are obliged to prepare written documentation that can form the basis for an assessment as to whether the prices and terms and conditions of the controlled transactions are in accordance with what could have been achieved if the transactions had taken place between independent parties.
Previously, the rule was that documentation had to be submitted upon request from the Tax Authority, but under new rules the documentation must be submitted automatically to the Tax Authority no later than 60 days after the deadline for submitting the tax return.