GTL Summary:

Cabinet Decision No. 39 of 2019, Article 54, requires linked entities to perform and report a 'functional analysis' in their tax returns. This analysis must describe the entity's economic role relative to its affiliates, identifying the specific functions performed, risks undertaken, and the tangible and intangible assets utilized. This documentation provides the Authority with a clear understanding of the value created by the entity, allowing for a more accurate assessment of whether its inter-company pricing aligns with the arm's length principle and the actual economic risks managed.