法律與法規命令
1.
Organizational structure:2.
General description of MNE’s businesses:(1)
Important drivers of business profit.(2)
A description of the supply chain and the main geographic markets for the group’s five largest products and/or service offerings by turnover plus any other products and/or services amounting to more than 5% of group turnover.(3)
A list and brief description of important service arrangements between members of the MNE Group, other than research and development (R&D) services, including a description of the capabilities of the principal locations providing important services and transfer pricing policies for allocating services costs and determining prices to be paid for intra-group services.(4)
An analysis describing the principal contributions to value creation by individual entities within the group, i.e., key functions performed, important risks assumed, and important assets used.(5)
A description of important business restructuring transactions, acquisitions, and divestitures occurring during the fiscal year.3.
MNE Group’s Intangible Assets:(1)
A general description of the MNE’s overall strategy for the development, ownership, and exploitation of Intangible Assets, including location of principal R&D facilities and location of R&D management.(2)
A list of Intangible Assets of the MNE Group that are important for transfer pricing purposes and which entities legally own them.(3)
A list of important agreements among constituent entities related to Intangible Assets, including cost contribution arrangements, principal research service agreements, and license agreements.(4)
A general description of the group’s transfer pricing policies related to R&D and Intangible Assets.(5)
A general description of any important transfers of interests in Intangible Assets among constituent entities during the fiscal year concerned, including the entities, countries or jurisdictions, and compensation involved.4.
MNE’s intercompany financial activities:(1)
A general description of how the group is financed, including important financing arrangements with non-members of the MNE Group.(2)
The identification of any members of the MNE Group that provide a central financing function for the group, including the country or jurisdiction under whose laws the entity is organised and the place of effective management of such entities.(3)
A general description of the MNE’s general transfer pricing policies related to financing arrangements between constituent entities.5.
MNE Group’s financial and tax positions:(1)
The MNE Group’s annual consolidated financial statement for the fiscal year concerned if otherwise prepared for financial reporting, regulatory, internal management, tax, or other purposes.(2)
A list and brief description of the MNE Group’s existing unilateral advance pricing agreements and other tax rulings relating to the allocation of income among countries.