Transfer Pricing Documentation definition

Transfer Pricing Documentation means any return, declaration, statement, report, claim, schedule, form or other documentation and any associated workpapers required for purposes of establishing any position with respect to transfer pricing purposes with any Taxing Authority (including documentation described in Section 6662(e) of the Code or the Organisation for Economic Co-operation and Development transfer pricing guidelines), as determined based on the past practice of the applicable member of the J&J Group or the Kenvue Group.
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Transfer Pricing Documentation. For all transactions entered into by the Corporation with any non-resident Person with which the Corporation was not dealing at Arm's Length during a taxation year commencing after 1997 and ending on or before the Closing Date, the Corporation has made or obtained records or documents that meet the requirements of paragraphs 247(4)(a) to (c) of the Tax Act.
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Examples of Transfer Pricing Documentation in a sentence

  • Except as otherwise provided in this Section 3.01 and Section 3.02, Kenvue shall prepare any Transfer Pricing Documentation with respect to a Kenvue Prepared Return and J&J shall prepare any Transfer Pricing Documentation with respect to a J&J Prepared Return.

  • The Party responsible under this Section 3.01(d) for preparing such Transfer Pricing Documentation shall provide a copy of such Transfer Pricing Documentation to the other Party upon such other Party’s reasonable request.

  • J&J and Kenvue shall (and shall cause the members of the J&J Group and the Kenvue Group, respectively, to) cooperate fully with all reasonable requests from the other Party in connection with the preparation and filing of Tax Returns and Transfer Pricing Documentation, the calculation of Taxes, the determination of the proper financial accounting treatment of a Return Item, the conduct or settlement of any Tax Contests and other matters covered by this Agreement.

  • Transfer Pricing Documentation For each Spyglass legal entity, in respect of any jurisdiction that requires such services, the Dell Transfer Pricing team will gather information and prepare required transfer pricing documentation that evidences the intercompany relationships between any Spyglass entities or between any Spyglass entities and any Dell entities, as applicable.

  • The Company has also Made Available to Parent the Transfer Pricing Documentation drawn up according to the Regulation issued by Italian Tax Authorities (Agenzia delle Entrate) on September, 29, 2010 together with all the supporting documents demonstrating the data and information contained therein.

  • This is similar to the European Union‟s Code of Conduct on Transfer Pricing Documentation for Associated Enterprises (EUTPD).