Accountants Report. Agenda. Legislative Framework in India. Importance of Form 3CEB. Form 3CEB Flow. Form 3CEB Clauses. Recent development

Transcription

1 Accountants Report Intensive Study Course Transfer Pricg ICAI Mumbai August 10, 2011 Presented By: Ms. Vaishali Mane Direcr Transfer Pricg Services Grant Thornn, India Agenda Legislative Framework India Importance Form 3CEB Form 3CEB Flow Form 3CEB Clauses Recent development Revisi Form 3CEB Management representati Letter Filg requirements or countries

2 Legislative Framework India Importance Form 3CEB Form 3CEB Flow Form 3CEB Clauses Recent development Revisi Form 3CEB Management Representati Letter Filg requirements or countries Legislative Framework Internatial Transacti Associated Enterprise Transfer Pricg applies Study Report Accountants Report

3 Legislative Framework India Importance Form 3CEB Form 3CEB Flow Form 3CEB Clauses Recent development Revisi Form 3CEB Management representati Letter Filg requirements or countries Importance a Form 3CEB Statury requirement India Provides a birds eye view transfer pricg/transactis assessee Assessg Officer ('AO') Helps AO refer transfer pricg matter special transfer pricg cell Helps transfer pricg ficer audit process Listg Associated enterprise Ctas a list Internatial transactis Highlights wher transactis are complex Ctas value ternatial transactis The transfer pricg methods followed

4 Or aspects Form 3CEB It must be furnished or bee due date applicable such pers or filg its return come relevant assessment year; No exempti from filg Form 3CEB - Even if ternatial transactis < 1 crore Under secti 271 BA Act, serted with effect from 1st April 2002, if a pers fails furnish this report, Assessg Officer may direct such pers shall pay way penalty, a sum Rs. 1 Lac Legislative Framework India Importance Form 3CEB Form 3CEB Flow Form 3CEB Clauses Recent development Revisi Form 3CEB Management Representati Letter Filg requirements or countries

5 Form 3CEB Flow Engagement assignment Checklist Verificati Process Management Representati Letter Issue Form 3CEB Form 3CEB Clauses Form 3CEB Engagement Process Pers enterg Internatial transacti obta report from an Accountant Accountant defed under Secti 288 Act Chartered Accountant s with meang Chartered Accountants Act, 1949 ( ); Statury Audir Communicate with or accountant who has de examati earlier years Engagement Letter Two or more CA's can do examati An accountant respsible writg or matenance accounts should exame accounts

6 Initially an be sent clients ctag a Blank mat / template Form 3CEB, Annexure Form 3CEB, Management Representati Letter Appendices same If client engagement has already been worked up last year attach files last year Or files Inmati be verified data collected - Checklist S. No. Particulars 1 Recciliati with related party - AS 18 2 Recciliati with Forex Transacti with respect Notes A/c 3 Sample Testg - Trial balance / Ledger A/c 4 Sample Invoice check/ debit es 5 PAN card copy available file 6 Form 27 - If applicable 7 Signed Audited Fancials 8 Segmental Fancials verified with audited accounts 9 Copies Agreement 10 Budgets/ Forecast 11 Management Representati Letter & Appendices re 12 Tax Assessment quiry

7 Form 3CEB We have examed accounts records, havg ir fice at, (PAN: relatg ternatial transactis entered assessee durg previous year ended. In our opi, proper mati documents as are prescribed have been kept assessee respect ternatial transactis entered, so far as appears from our examati records assessee. The particulars required be furnished under secti 92E are given Annexure this Form. In our opi best our mati accordg explanatis given us, particulars given Annexure are true correct. Case Study 1 Form 3CEB a Permanent Establishment ('PE') India

8 Legislative Framework India Importance Form 3CEB Form 3CEB Flow Form 3CEB Clauses Recent developments Revisi Form 3CEB Management Representati Letter Filg requirements or countries Clauses Form 3CEB Stard Inmati filled up all clauses Particulars taxpayer Clauses 1 6 Particulars 's with whom taxpayer has entered ternatial transacti Clause 7 Particulars respect Internatial transactis Tangible property Clause 8 Intangible property Clause 9 Services Clause 10 Lendg Borrowg Mey Clause 11 Mutual Agreement/Arrangement Clause 12 Any or transacti Clause 13

9 Clauses 1 6 Name assessee New old name be disclosed Address assessee In case Branch In case Company In case Foreign company or a PE Permanent Account Number Status Previous Year ended Assessment year Clause 7: Details Name addresses The relevant sub clause secti 92A (2) under which such relatiship is covered should also be provided ; In most cases, relatiship would fall under sub clause (a) or (b) out thirteen sub clauses; Additial care should be taken cases fallg under or clauses; Deemed Note be disclosed

10 Clause 7: Details Clause 7 Inmati respect Associated Enterprises ('s) Sr. No. Name address 1 XYZ Corporati USA, P.O Box 661, Lville Road, Mt.Airy, New York, USA nc Nature relatiship with (Refer Note 1 Below) 100% Subsidiary Company under Secti 92A(1)(a) read with Secti 92A(2)(a) Brief descripti 's busess Manufacturg & Tradg products Notes: 1 Sectis mentied above refer sectis Income-tax Act, Clause 8A 8B: Raw Materials Fished Goods 1. Transactis be disclosed Clause 8A 8B 2. Cross-check purchase/sale transactis raw materials / fished goods with AS As regards purchase raw materials, ascerta wher same are used furr manufacturg process or sold a third party manufacture or resold. 4. See Ledger Account correctness amount 5. Sample Invoices product sold 6. Descripti product or termology describg product

11 Clauses Form 3CEB Clause 8A Particulars respect Tangible Property - Purchase / Sale Raw Materials Sr. No. Name address Descripti transacti 1 XYZ Corporati USA, Purchase P.O Box 661, Lville Road, Packg Mt.Airy, New York, material USA nc Quantity purchased (Refer Note 2 below) Total Amount paid / payable as per books Total Amount paid / payable as per Arm's Length Price (as computed assessee) (Refer Note 1 below) Method Used (Rs.) [See Secti 92C(1)] Nos 523, ,566 Transactial Net Marg Method ('TNMM') Notes: 1 As per Transfer Pricg study undertaken assessee, Transactial Net Marg Method determed be most appropriate method prescribed under Secti 92C Income-tax Act, On basis study, it ccluded prices ternatial transactis assessee at arm s length as provided under secti 92C Income-tax Act, Accordgly, it csidered reasable use book values ternatial transactis as representative arm s length price all such transactis. 2 Although quantities spare parts/ csumables/ packg materials have been stated y are different grades. Clauses Form 3CEB Clause 8B Particulars respect Tangible Property Import / Export Fished Goods Sr. No. Name address 1 XYZ Corporati USA, P.O Box 661, Lville Road, Mt.Airy, New York, USA nc Descripti transacti Sale Fished Goods Class Transacti Manufacturg Export Quantity Sold Pairs (Refer Note 2 below) Total Amount received / receivable as per books Total Amount received / receivable as per ALP (Refer Note 1 below) Method Used (Rs.) 8,624, ,963, ,963,573 Transactia l Net Marg Method ('TNMM') Notes: 1 As per Transfer Pricg study undertaken assessee, Transactial Net Marg Method determed be most appropriate method prescribed under Secti 92C Income-tax Act, On basis study, it ccluded prices ternatial transactis assessee at arm s length as provided under secti 92C Income-tax Act, Accordgly, it csidered reasable use book values ternatial transactis as representative arm s length price all such transactis. 2 Although quantities socks have been stated y are different grades.

12 Clause 8C: Tangible Movable/Immovable Property 1. Disclose details Assets purchased / sold 2. Review Asset Purchase Agreement 3. Valuati certificate issued an expert 4. Shares purchased /sold 5. Free cost assets 6. Assets purchased abroad sold India back back basis 7. Transfer assets India at Book Value relevant documents 8. Documents related cusms valuati 9. Some examples Clauses Form 3CEB Clause 8C Particulars respect Tangible Moveable/Immoveable Property - Purchase / sale Capital Assets Total Amount paid / Sr. No. Name address Descripti property nature transacti Class Transacti Number units payable as per Total Amount each category Arm's Length Price paid / payable as moveable / (as computed per books immovable assessee) property (Refer Note 1 below) Method Used (Rs.) [See Secti 92C(1)] 1 XYZ Corporati USA, Purchase Import plant & 1 No. 13,956 13,956 Comparable Unctrolled P.O Box 661, Lville Fixed Assets Machery Price Method ('CUP') Road, Mt.Airy, New York, USA nc Notes: 1 As per Transfer Pricg study undertaken assessee, Comparable Unctrolled Price Method determed be most appropriate method prescribed under Secti 92C Income-tax Act, On basis study, it ccluded prices ternatial transactis assessee at arm s length as provided under secti 92C Income Tax Act, Accordgly, it csidered reasable use book values ternatial transactis as representative arm s length price all such transactis.

13 Clause 9: Intangible property Internatial transacti(s) respect purchase/sale/use tangible property such as know-how, patents, copyrights, licenses, etc For royalty CUP is preferred method (where we fd comparable agreements usg Royalty Stat, Lexis Nexis etc.) IF CUP is undertaken, TNMM could be used as most appropriate method test arm s length nature royalty payment (assumg aggregati transactis is possible) RBI approvals? Clause 9: Intangible property Obta review agreements. Ascerta nature benefits received from payment royalty, designs, technical drawgs, know how etc. Obta Secti 195 certificate, if necessary. To ascerta impact royalty payment ternal / external TNMM, review impact royalty payments pritability relevant segment. Check if re is any CUP (royalty paid third party bee enterg ctract with group entity). Also, check CUP or countries ( if applicable) Review Group policy ascerta if any or group entity avails same / similar technical know-how at prescribed rate. Verify calculati royalty payments. Verify TP Report overseas entity ( if any)

14 Clauses Form 3CEB Clause 9 Particulars respect transactis Intangible Property Sr. No. Name address with whom ternatial transacti has been entered 1 XYZ Inc 1313, N. Market Street, Wilmgn DE , UK. Descripti each transacti Royalty Technical knowhow Total Amount paid / payable as per books (Refer Note 2 below) Total Amount paid / payable as per Arm's Length Price (as computed assessee) (Refer Note 1below) Method used determg arm's length price 6,828,753 6,828,753 Comparable Unctrolled Price Method. Notes: 1 As per Transfer Pricg study undertaken assessee, Comparable Unclled Price Method determed be most appropriate method prescribed under Secti 92C Income Tax Act, On basis study, it ccluded prices ternatial transactis assessee at arm s length as provided under secti 92C Income-tax Act, Accordgly, it csidered reasable use book values ternatial transactis as representative arm s length price all such transactis. Clause 10: Services Covers ternatial transacti(s) respect such as fancial, admistrative, technical, commercial, etc Review Agreements renderg /receivg Nature rendered Compensati model Ownership IP Payment terms comparable terms Group Policy Ledger Accounts, Invoices

15 Clause 10: Services Verify a test check basis documents availed: s Mutes cference calls case any advice received In case actual visits eign employees, details tickets, hotel bills, rendered while India Review TDS certificates, if any Clauses Form 3CEB Clause 10 Particulars respect provided / availed f Sr. No. Name address with whom ternatial transacti has been entered Descripti provided Amount received or receivable provided As per books accounts Arms' length price as computed assessee (Refer Note 1) (Rs.) Method used determg arm's length price [See Secti 92C(1)] 1 XYZ Inc. 101,Ma Street, 16th Floor, Cambridge. Massachusetts ,USA Renderg Stware Devlopment 159,030, ,030,979 Transactial Net Marg Method Notes: 1 As per Transfer Pricg study undertaken assessee, Transactial Net Marg Method determed be most appropriate method prescribed under Secti 92C Income Tax Act, On basis study, it ccluded prices ternatial transactis assessee at arm s length as provided under secti 92C Income-tax Act, Accordgly, it csidered reasable use book values ternatial transactis as representative arm s length price all such transactis.

16 Clause 11: Lendg Borrowgs Internatial transacti(s) respect grantg/receivg loans/ advances Name address Nature fancg arrangement Currency Interest rates Clause 11: Lendg Borrowgs Review loan agreements. Refer AS-18 Related Party Transactis disclosures loan transactis. Check loans taken/given repaid durg year itself Interest free loans given Indian entity Case Laws Perot Systems TSI India Private Limited Case Laws VVF Limited In case Interest free loans given, exame possibility adjustment. Insist a robust loan/terest rate benchmarkg mitigate possible risk exposure.

17 Clauses Form 3CEB Clause 11 Particulars respect lendg / borrowg mey grantg / receivg loans / advances / from associated enterprise Sr. No. Name address with whom ternatial transacti has been entered 1 XYZ Corporati USA, P.O Box 661, Lville Road, Mt.Airy, New York, USA nc Nature transacti Currency which advance received Interest rate paid respect advance Loan USD LIBOR + 2% Amount paid / payable As per books Accounts Arm's length price as computed assessee Method used determg Arm's Length Price ( Rs.) [See Secti 92C(1)] xxxx xxxx Comparable Unctrolled Price Method Notes: 1 As per Transfer Pricg study undertaken assessee, Comparable Unclled Price Method determed be most appropriate method prescribed under Secti 92C Income Tax Act, On basis study, it ccluded prices ternatial transactis assessee at arm s length as provided under secti 92C Income-tax Act, Accordgly, it csidered reasable use book values ternatial transactis as representative arm s length price all such transactis. Clause 12: Mutual Agreements /Arrangements This clause deals with mutual agreement or arrangement allocati or apportiment, or any ctributi, any cost or expense curred or be curred cnecti with a benefit, service or facility provided or be provided any e or more such enterprises Particulars be provided: Name address Descripti mutual agreement/ arrangement Amount As per books ALP Method use Type transactis covered Cost Allocati / Cost sharg Arrangements Review Agreements

18 Clauses Form 3CEB Clause 12 Sr. No. Particulars respect Mutual Agreement or Arrangement Name address 1 XYZ Corporati USA, P.O Box 661, Lville Road, Mt.Airy, New York, USA nc Descripti mutual agreement / arrangement Total Amount received / receivable as per books Total Amount received / receivable as per Arm's Length Price (as computed assessee) (Refer Note 1) Method Used Rs. Management Fees xxxx xxxx Transactial Net Marg Method ('TNMM') Notes: 1 As per Transfer Pricg study undertaken assessee, Transactial Net Marg Method determed be most appropriate method prescribed under Secti 92C Income-tax Act, On basis study, it ccluded prices ternatial transactis assessee at arm s length as provided under Secti 92C Income-tax Act, Accordgly, it csidered reasable use book values ternatial transactis as representative arm s length price all such transactis. Management Service Fees Gemplus India Pvt. Ltd. Facts Case: Gemplus Gemplus Sgapore Sgapore As per Management Services Agreement (MSA), Gemplus India s s would provide need-based. 100% Renders marketg sales support, cusmer service support, fance, accountg admistrati support legal support. Services rendered billed s basis time spent with an overall fixed cap. Selected TNMM as MAM. Gemplus Gemplus India India Pvt. Pvt. Ltd. Ltd. TPO ctended management fees paid s deductible as taxpayer did prove commensurate benefits accrued from se. Taxpayer failed prove aspects, management service fees at ALP hence allowable.

19 Management Service Fees Gemplus India Pvt. Ltd. Gemplus s ctenti TPO / CIT(A) ctenti ITAT ctenti Commendable Commendable Sales Sales turnover turnover achieved, achieved, which which would would have have been been possible possible without without rendered rendered exclusively exclusively busess busess assessee assessee Taxpayer Taxpayer did did derive derive any any specific specific benefit benefit from from management management hence hence payment payment wards wards management management justified justified disallowed disallowed expenses expenses claimed. claimed. Imperative Imperative part part Taxpayer Taxpayer establish establish payment payment made made commensurate commensurate volume volume quality quality such such cost cost are are comparable. comparable. There There no no material material records records show show no no rendered rendered payments payments excessive excessive compared compared analogous analogous transacti. transacti. MSA MSA has has been been entered entered bee bee FY, FY, hence hence possible possible ctemplate ctemplate nature nature volume volume ir ir compensati compensati No No details details available available records records with with respect respect nature nature rendered rendered Taxpayer Taxpayer,, hence, hence, TPO TPO justified. justified. Management Service Fees Gemplus India Pvt. Ltd. Gemplus s ctenti TPO / CIT(A) ctenti ITAT ctenti Employed Employed a a hful hful perss perss India India all all technical technical expertise expertise provided provided a a need need basis. basis. Taxpayer Taxpayer already already has has qualified qualified persnel persnel its its service service India India Taxpayer Taxpayer has has already already curred curred expenditure expenditure similar similar.. TNMM, TNMM, could could be be accepted accepted determe determe AL AL nature nature fees fees as as payment payment terms terms dependent dependent nature nature or or volume volume Services Services rendered rendered billed billed basis basis time time spent spent rendered rendered Taxpayer, Taxpayer, with with an an overall overall fixed fixed cap. cap. Cost Cost has has been been apportied apportied different different countrycentres countrycentres a a mutually mutually agreed agreed basis basis basis basis actual actual rendered. rendered. TPO TPO justified. justified. Taxpayer Taxpayer failed failed prove prove benefit benefit test, test, management management fees fees at at arm s arm s length length hence hence allowed. allowed. Benefit test robust documentati are keys provg management fees be at ALP

20 Clause 13: Or Transactis Any or ternatial transacti specifically referred above Transactis reported clause 13 perta re imbursements expenses Free cost transactis disclosed way a e Documentary evidence be reviewed: Nature reimbursement expenses descripti Debit es underst descripti expenses charged / recovered Support documents vouchers Clauses Form 3CEB Clause 13 Particulars respect any or transactis - Reimbursements / Ors Receipts / Or payments Sr. No. Name address 1 XYZ Corporati USA, P.O Box 661, Lville Road, Mt.Airy, New York, USA nc Descripti each transacti Reimbursement travellg Total Amount paid / payable as per books Refer Note 2 below Total Amount paid / payable as per Arm's Length Price (as computed assessee) (Refer Note 1) Method Used Rs. [See Secti 92C(1)] 18,025 18,025 Comparable Unctrolled Price Method ('CUP') Notes: As per Transfer Pricg study undertaken assessee, Comparable Unctrolled Price Method determed be most appropriate method prescribed under Secti 92C Income-tax Act, On basis study, it ccluded prices ternatial transactis assessee at arm s length as provided under Secti 92C Income-tax Act, Accordgly, it csidered reasable use book values ternatial transactis as representative arm s length price all such transactis.

21 Legislative Framework India Importance Form 3CEB Form 3CEB Flow Form 3CEB Clauses Recent development Revisi Form 3CEB Management Representati Letter Filg requirements or countries Recent development Amadeus India Pvt. Ltd. Facts Case: Amadeus Associated Enterprises s Amadeus India Pvt. Ltd. Amadeus India Provides data processg related its s. Respsible providg stware access subscribers Amadeus products computer database with Indian subctent. TNMM selected as MAM - PLI selected as OP/TC - TPO did raise any objecti method adopted or computati ALP TPO alleged assessee had curred more than normal sales marketg expenses build amadeus br, which is legally owned Amadeus Spa. TPO compared AMP/Sales% 3 companies 12.16% with assessee s AMP% 40.87%, hence addg a mark-up 10% more than normal marketg expenses TPO passed a draft order, later cfirmed DRP

22 Marketg Intangibles Amadeus India Pvt. Ltd. Amadeus s ctenti TPO / CIT(A) ctenti ITAT ctenti Incurred Incurred normal normal sales sales marketg marketg expenses expenses as as same same disallowed disallowed AO AO u/s u/s 37(1) 37(1) AMP AMP expenses expenses 3 3 rd rd party party expenses expenses same same recognised recognised assessee assessee as as an an ternatial ternatial transacti transacti Form Form 3CEB 3CEB TPO TPO did did cclude cclude AMP AMP expenditure expenditure curred curred is is an an ternatial ternatial transacti transacti Assessee Assessee had had curred curred more more than than normal normal sales sales marketg marketg expenses expenses build build br br India, India, which which is is legally legally owned owned Amadeus Amadeus Spa. Spa. When When a a file file is is referred referred TPO, TPO, AO AO is is referrg referrg entire entire gamut gamut ternatial ternatial transactis transactis AMP AMP expenditure expenditure should should be be csidered csidered as as an an ternatial ternatial transacti transacti with with meang meang Secti Secti 92B(1) 92B(1) Act Act Deleti Deleti AMP AMP expenditure expenditure related related adjustments adjustments made made TPO TPO as as he he acted acted beyd beyd his his jurisdicti, jurisdicti, without without approval approval from from CIT CIT The The role role TPO TPO is is restricted restricted ly ly transacti, transacti, referred referred him him AO AO (CBDT (CBDT Inst. Inst ) 2003) Pla Pla readg readg Sec. Sec. 92CA(1) 92CA(1) nowhere nowhere reveals reveals TPO TPO can can take take any any transacti transacti suo suo mo mo verificati verificati adjustment adjustment Marketg Intangibles Amadeus India Pvt. Ltd. Amadeus s ctenti TPO / CIT(A) ctenti ITAT ctenti Avoidance Avoidance tax tax cditi cditi precedent precedent vokg vokg TPR TPR The The TPR TPR does does require require m m but but also also overall overall arrangement/substance arrangement/substance transactis transactis bee bee determg determg ALP. ALP. Assessee Assessee curred curred costs costs under under a a mutual mutual agreement, agreement, writg, writg, but but proved proved from from cduct cduct parties parties Bright Bright Le Le Test Test de de TPO TPO applyg applyg AMP/Sales AMP/Sales as as a a base base benchmarkg benchmarkg is is methods methods prescribed prescribed under under TPR TPR India India Proposed budget 2011 gives TPO power evaluate transacti referred AO

23 Recent development Open Technologies India Private Limited Facts Case: Assessee had furnished Accountants Report bee due date filg ROI AY Had obtaed Form 3CEB September 1, 2006 which bee due date Penalty proceedgs under Secti 271 BA Act itiated AO Open Technologies India Private Limited Taxpayer s ctenti AO / CIT(A) ctenti ITAT ctenti Onle Onle filg filg return return mary mary first first time time Ne Ne documents documents filed filed like like audited audited accounts, accounts, TDS TDS certificate, certificate, Form3CEB Form3CEB etc etc Form Form 3CEB 3CEB filed filed due due course course assessment. assessment. Affidavit Affidavit from from Direcr Direcr CA CA submitted submitted Form Form 3CEB 3CEB obtaed obtaed AO AO did did accept accept ctenti ctenti levied levied penalty penalty under under Secti Secti BA BA CIT CIT (A) (A) upheld upheld penalty penalty levied levied AO AO Assessee Assessee had had obtaed obtaed Form Form 3CEB 3CEB bee bee due due date date return return filg filg Secti Secti 273B 273B provides provides no no penalty penalty under under Secti Secti BA BA will will be be leviable leviable if if re re is is reasable reasable case case failure failure comply comply Penalty deleted Assessee Assessee under under genue genue belief belief Annexures Annexures be be filed filed with with return. return.

24 Legislative Framework India Importance Form 3CEB Form 3CEB Flow Form 3CEB Clauses Recent development Revisi Form 3CEB Management Representati Letter Filg requirements or countries Revisi Form 3CEB Prior Merger Facts Case: K Ltd, M Ltd C Ltd are separate legal entities India Out India They have filed ir Form 3CEB April 2009 March 2009 September 2009 K Ltd Ltd M Ltd Ltd C Ltd Ltd In India The group wants merge K ltd M Ltd C Ltd have a sgle entity India The Scheme Amalgamati is approved High Court Ocber 2009 w.e.f January 1, 2009.

25 Revisi Form 3CEB Post Merger Out India Form Form 3CEB 3CEB filed filed entities entities are are revised revised In India April March April Dec April Dec C Ltd Ltd K Ltd Ltd M Ltd Ltd Revisi Form 3CEB No specific provisis Income tax Act revisi Form 3CEB Guidance Note silent this No legal precedent Revisi Form 3CEB transacti affects come reported Return Income Secti 139 (5)

26 Revisi Form 3CEB Some examples Transacti disclosed Wrg amount has been disclosed Wrg details have been disclosed Origal 3CEB based unaudited fancials revised 3CEB is based audited fancials Legislative Framework India Importance Form 3CEB Form 3CEB Flow Form 3CEB Clauses Recent Developments Revisi Form 3CEB Management Representati Letter Filg requirements or countries

27 Management Representati Letter Inmati Documents mataed Study Report Ownership Structure Details Associated Enterprises ternatial transactis with associated enterprises Segmental Fancials Company Cfirmati eign currency disclosures Cfirmati re - imbursements expenses Legislative Framework India Importance Form 3CEB Form 3CEB Flow Form 3CEB Clauses Recent developments Revisi Form 3CEB Management Representati Letter Filg requirements or countries

28 Filg Requirements US UK US Filg Form Copy CSA Statement filed UK Ne Specified Filg Requirements Western Europe Spa Disclose details RPT ms filed returns Nerls Returns clude e questi wher any RPT Italy State wher TP document mataed Total amount all RPT Germany Ne France Ne

29 Filg Requirements Asia Malaysia Transactis with related party be disclosed Vietnam Form GCN-01/QLT be filed Form be filed with 90 days from year end Indesia 3A Identity related party transacti detail 3A-1 Existence study support ALP Thail No disclosure Thank you