Article 56

A linked entity must provide the necessary information to the Authority to identify and assess its transfer pricing risks and to audit its transfer pricing practices.

It must submit a transfer pricing statement with its annual tax return using the form prepared by the Authority if its total revenue or total assets shown in its balance sheet meet or exceed the threshold set by the Authority.

The Authority may request additional information from a linked entity within a maximum of thirty days from the date of the request to aid in assessing transfer pricing risks or auditing its practices. The Authority may also provide a transfer pricing questionnaire tailored to the areas it specifies.

During a tax audit, the Authority may require a linked entity to supplement the information provided in the transfer pricing form or questionnaire with additional documents and information.