Update local country file – Limited risk distributor

Detailed information

This template is typically used to update the Local file for a limited risk distributor (prepared as per BEPS Action 13 / OECD Guidelines) for previous year in a simple and easy to follow manner.

This update template is designed under the assumption that the relevant facts and circumstances for the company under review did not change significantly vis-à-vis the previous year. This implies that the functional and risk profile of the limited risk distributor and the intercompany transactions it was involved in remained largely the same.

This update template addresses the controlled transactions in which the limited risk distributor was engaged in during the most recent year, reconfirms the functional and risk profile of the limited risk distributor and selected transfer pricing method (also containing language in case an update of the benchmark study is conducted). In addition, the update template details specific financial and tax information and includes the relevant appendices supporting the above-mentioned.

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Update local country file – Limited risk distributor

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