GTL Summary:

Cabinet Decision No. 39 of 2019, Article 61, establishes that full documentation does not preclude tax adjustments. Claiming that other linked entities are responsible for compliance does not excuse an entity from its local documentation duties. Crucially, even if an entity provides comprehensive records, the Authority reserves the right to adjust transaction prices if they are found not to be at arm's length. This article ensures that local entities remain fully accountable and that documentation is viewed as a tool for verification, not an automatic guarantee of price acceptance.