GTL Summary:

Cabinet Decision No. 39 of 2019, Article 62, mandates the retention of all transfer pricing information and documents concerning transactions with linked entities. Entities must comply with the general legal retention requirements (as established in Article 36) to ensure that records are available for review by the Authority for the specified ten-year period. This ensures long-term auditability of inter-company pricing and provides a historical record of compliance with the arm's length principle, which is essential for defending tax positions during future audits or disputes.