GTL Summary:

Cabinet Decision No. 39 of 2019, Article 58, clarifies the Authority's use of transfer pricing documentation. It explicitly states that the Authority may rely on the information provided in the Master and Local files to assess transfer pricing risks and to conduct detailed tax audits. By using these files, the Authority can identify inconsistencies in pricing or high-risk inter-company arrangements. This article highlights the importance of accurate and thorough file preparation, as these documents serve as the primary evidence during regulatory reviews and enforcement actions.