Enhanced Transfer Pricing Documentation Requirements for Transactions Involving Non-Cooperative Tax Jurisdictions

The Anti-Tax Havens Act contains a number of defensive measures regarding business transactions involving uncooperative states. As of 1 January 2022, among other requirements, the taxpayer has to carry out certain enhanced transfer pricing documentation conditions in such business transactions. Specifically, this means transfer pricing documentation must be submitted at a particularly early stage and must also include transactions with third parties.