3 wishlist for transfer pricing documentation (TPD) on SME for the Budget 2022.

SME is required to prove group and related party transactions to be arm length under Section 140A of The Income Tax Act 1967 (ITA).

Problems to SME for TBD compliance

How many SME understand arm length?
How many SME afford the fee for transfer pricing documentation?
How many SME know benchmarking testing, functional analysis, cost plus method?

Wishlist for SME on TPD

Exemption below certain threshold.
Safe harbour ruling where 5% mark up on low value added service is acceptable.
IRB publish arm length rate/data to SME.

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