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Transfer Pricing Local File Template (OECD Chapter V Annex II)

OECD-style local file: entity, controlled transactions, FAR analysis, method selection, comparables search, interquartile range, segmentation, true-up, US 6662 cross-reference

Finance, Investissement & ComptabilitéCompletOECD Transfer Pricing Guidelines 2022, Chapter V Annex II; Vietnam Decree 255/2026/ND-CP; Treas. Reg. 1.6662-6transferpricinglocalfilemath

Mode d'emploi: Use it when a group entity must show that its intercompany transactions are at arm's length for its local tax authority. Fill the exemption test and the controlled-transactions table first, then the functional analysis and the benchmark. The main pitfall is an interquartile range computed with a different convention or cost base than the local rule requires.

Aperçu

Transfer Pricing Local File: [Local entity name] FY[YYYY]

Entity-level transfer pricing documentation (the "local file") for one taxpayer in a multinational enterprise (MNE) group: the local entity and its management, each category of controlled transaction, the functional analysis, method selection, comparables search, arm's length range, adjustments, conclusion and the reconciliation to the local financial statements. Structure follows the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, Chapter V, Annex II, with a cross-reference to local rules in Vietnam, Germany, the United Kingdom and the United States (as of 2026-10). Replace every [bracketed] value and every row marked Example. This is a document format, not tax, legal, accounting or financial advice. Requirements are referenced by number: obtain the guidelines or the law for the normative text.

Document control

FieldValue
Document ID[TP-LF-VN-FY2026]
Version[1.0]
Status[Draft / In review / Approved / Superseded]
Taxpayer[Legal name, tax ID] Example: Ostrander Vietnam Co., Ltd (OST-VN), tax ID [0000000000]
Jurisdiction[Country] Example: Vietnam
Financial year[YYYY-MM-DD to YYYY-MM-DD] Example: 2026-01-01 to 2026-12-31
Currency and units[EUR thousand; VND million in local tables]
Related master file[TP-MF-FY2026]
Owner[@local-finance-director]
Prepared by[@tp-manager], [External adviser, if any]
Approvers/reviewers[@head-of-tax], [@legal-representative], [@cfo]
Last updatedYYYY-MM-DD
Classification[Confidential: tax authority and authorised staff only]
Language[English and Vietnamese; Vietnamese version provided on request]

Approvals

RoleNameDecisionDate
Local legal representative or general director[@name][Approve / Return]YYYY-MM-DD
Group Head of Tax[@name][Approve / Return]YYYY-MM-DD
External adviser review (optional)[Firm, @name][Reviewed]YYYY-MM-DD

Revision history

VersionDateAuthorChange
0.1YYYY-MM-DD[@author]Draft with FY financial data and prior-year benchmark rolled forward
0.9YYYY-MM-DD[@author]Benchmark refreshed, segmentation reviewed
1.0YYYY-MM-DD[@author]Approved

Contents

1. Purpose, scope and legal basis

1.1 Purpose

This local file documents the controlled transactions of [Local entity] with associated enterprises for [YYYY], explains how they were priced, and demonstrates that the results are consistent with the arm's length principle. It supports the corporate income tax return and the related party disclosures for the year.

Example: Ostrander Vietnam Co., Ltd provides software development services to its parent and resells a small volume of point-of-sale hardware bought from the parent. Both flows are controlled transactions. The file shows that the development segment earned a net cost plus of 8.0%, inside the interquartile range of comparable independent service providers, and that the resale segment earned an operating margin inside its own range.

1.2 Local requirements (as of 2026-10)

Check local law: thresholds, deadlines and forms change.

JurisdictionLegal basis (as of 2026-10)Local file duty and exemptionsTiming and language
VietnamDecree 255/2026/ND-CP, effective 2026-07-01, applies from the 2026 corporate income tax periodTaxpayers with related-party transactions prepare documentation unless exempt; exempt if revenue is below VND 500bn, there is no revenue or cost from exploiting intangibles, and the net margin is at least 5% (distribution), 10% (manufacturing) or 15% (processing); the former simple-function condition is removedPrepare before the corporate income tax finalisation return; provide on request within the period the decree sets (confirm); Vietnamese language for submissions (confirm)
GermanySection 90(3) and (4) AO; GAufzV section 4Every entity with cross-border related-party transactions keeps a transaction matrix and local documentation; small-entity relief in GAufzV section 630 days from a request; in a tax audit, the transaction matrix and records of extraordinary transactions are due within 30 days of the audit order
United KingdomSI 2023/818Local file in OECD format for UK entities of groups with consolidated revenue of EUR 750m or more, periods from 2023-04-01Produce within 30 days of an HMRC request
United StatesIRC section 6662(e); Treas. Reg. 1.6662-6(d)(2)(iii)Documentation optional but needed for penalty protection; ten principal documentsIn existence when the return is filed; provide within 30 days of an IRS request
[Other][Law][Duty][Timing]

1.3 Exemption and scope test

TestValueResult
Total revenue FY2026 (Example)EUR 131,640k; VND 3,751,740m at an average rate of VND 28,500 per EURAbove the VND 500bn exemption threshold
Revenue or costs from exploiting intangibles (Example)None: all development results vest in OST-NLNot relevant once the revenue test fails
Conclusion (Example)Full local file required for FY2026

Check: 131,640 x 28,500 = 3,751,740,000 thousand VND = VND 3,751,740m (about VND 3,751.7bn).

Use the exchange rate the local rule specifies for the test (for example the rate used in the statutory accounts). If revenue sits close to a threshold, document the rate source, because a different rate can change the result.

2. Local entity

2.1 Management structure and reporting lines

RoleName or positionEmployerReports to (country)
General director (Example)[Name]OST-VNGroup CTO (Netherlands)
Engineering managers (6) (Example)[Names]OST-VNGeneral director (Vietnam); product owners in the Netherlands for priorities
Finance manager (Example)[Name]OST-VNGroup controller (Netherlands)
Resale sales lead (Example)[Name]OST-VNGeneral director (Vietnam)

2.2 Business and strategy

Example: OST-VN was set up in 2021 in Ho Chi Minh City as the group's main engineering centre. At the end of FY2026 it employed 2,900 people, of whom 2,850 were engineers, testers and designers. Its strategy for 2027 is to add about 300 engineers while keeping cost per full-time equivalent below the group target set in the annual budget. A team of 40 resells point-of-sale hardware to Vietnamese merchants who use the Ostrander platform.

2.3 Restructurings and transfers of intangibles

Example: On 2026-04-01 40 engineering roles moved from OST-NL to OST-VN (master file CHG-001 and RST-001). The roles perform development under the existing services agreement. No intangible, customer list or decision-making function moved, so no compensation for a transfer arose.

2.4 Key competitors

List the main competitors in each activity. Example: For development services, independent software outsourcing firms in Vietnam and the region compete for the same engineers and clients. For resale, local resellers of point-of-sale hardware compete on price and delivery time.

3. Controlled transactions

3.1 Transactions by category

Transaction IDCategoryCounterparty (country)DirectionFY2026 amount (EUR thousand)VND millionPolicyAgreement
CT-001 (Example)Software development servicesOST-NL (Netherlands)Income116,6403,324,240TPP-002AGR-001
CT-002 (Example)Purchase of point-of-sale hardware for resaleOST-NL (Netherlands)Expense12,000342,000TPP-001 (resale variant)AGR-003
CT-003 (Example)Group support services (finance, HR, IT)OST-NL (Netherlands)Expense1,50042,750TPP-003AGR-004
[CT-NNN][Category][Entity][Income / Expense][Amount][Amount][Policy][Agreement]

Check: 116,640 x 28.5 = 3,324,240; 12,000 x 28.5 = 342,000; 1,500 x 28.5 = 42,750 (VND million at VND 28,500 per EUR).

3.2 Intercompany agreements

Agreement IDTitlePartiesEffective dateKey terms relevant to pricing
AGR-001 (Example)Contract research and development services agreementOST-VN, OST-NL2022-01-01Results vest in OST-NL; fee equals total operating costs plus 8%; OST-NL approves statements of work; quarterly invoices, 60-day payment
AGR-003 (Example)Supply agreement for resaleOST-NL, OST-VN2023-03-01Transfer price set to give OST-VN a target operating margin; OST-NL takes back obsolete stock
AGR-004 (Example)Group services agreementOST-NL and subsidiaries2021-07-01Allocated cost plus 5%, allocated by a weighted key of external revenue and system users (50% each); OST-VN share EUR 1,500k

Attach copies. Where conduct differs from the written terms, describe the actual conduct, because the accurate delineation of a transaction follows what the parties actually do.

3.3 Intercompany balances at year end

CounterpartyReceivable (EUR thousand)Payable (EUR thousand)Days outstandingComment
OST-NL (Example)19,5001,80061 (receivable)Within the 60-day term plus normal processing; no interest charged

4. Functional, asset and risk analysis

4.1 Functions

FunctionOST-VNOST-NLEvidence
Decide which products and features to build (Example)MinorMajorProduct committee minutes in the Netherlands
Write, test and document code (Example)MajorModerateSprint records, time sheets
Recruit and manage engineers (Example)MajorMinorHiring records, local HR
Quality assurance and release approval (Example)ModerateMajorRelease sign-off log
Sell hardware to Vietnamese merchants (Example)MajorNoneSales invoices
Set resale prices and stock levels (Example)ModerateMajorGroup price list, stock approvals

4.2 Assets

Example: OST-VN uses office leases, laptops, test devices and servers (tangible assets of EUR 18,000k net book value at year end) and an experienced workforce. It does not own intangibles: code, designs and documentation it produces belong to OST-NL under AGR-001. For resale it holds a small hardware stock (average EUR 1,500k).

4.3 Risks

Apply the six-step process for analysing risk in Chapter I of the OECD Guidelines: identify the economically significant risks, map contractual allocation, determine which party performs control functions and has the financial capacity, check whether conduct matches contract, and allocate risk to the party that controls it.

Risk IDRiskContractual allocationControl functions performed byFinancial capacityConclusion
RSK-001 (Example)Development risk (a project fails or is abandoned)OST-NLOST-NL product committeeOST-NLBorne by OST-NL; OST-VN is paid for effort regardless of outcome
RSK-002 (Example)Service capacity risk (idle engineers)OST-NL through cost-plus on all costsOST-NL decides demand; OST-VN manages hiringOST-NLMainly OST-NL; OST-VN bears operational execution risk
RSK-003 (Example)Foreign exchange risk on EUR invoicesOST-VNOST-VN finance with group treasury policyOST-VNBorne by OST-VN; FX result excluded from operating profit
RSK-004 (Example)Inventory risk on resale stockOST-NL takes back obsolete stockOST-NL approves stock levelsOST-NLLimited for OST-VN
RSK-005 (Example)Credit risk on Vietnamese merchantsOST-VNOST-VNOST-VNBorne by OST-VN (low: prepayment terms)

4.4 Characterisation

Example: For CT-001, OST-VN is a contract software service provider: it performs routine development under the direction of OST-NL, owns no intangibles and bears limited risk. For CT-002, it is a limited-risk reseller. OST-NL is the entrepreneur that controls development and market risks and owns the platform.

5. Method selection

The OECD Guidelines (Chapter II) describe five methods: comparable uncontrolled price (CUP), resale price, cost plus, transactional net margin method (TNMM) and transactional profit split. Select the most appropriate method for each category and record the reasons for rejecting the others.

MethodCT-001 development servicesReason
CUP (Example)RejectedNo reliable price for identical development services between independent parties; internal comparables do not exist because OST-VN serves only the group
Resale price (Example)RejectedNot a resale transaction
Cost plus (gross) (Example)RejectedGross margin data of comparables are not reported consistently; cost classifications differ
TNMM (Example)SelectedOST-VN is the less complex party; reliable net margin data are available for independent service providers
Profit split (Example)RejectedOST-VN makes no unique and valuable contribution; integration is not so high that one-sided testing fails

For CT-002 (resale), TNMM with operating margin on sales was selected for the same reasons; for CT-003 (group services), the cost-plus charge under the low value-adding services approach is tested in the provider's file and checked here for the benefit test (the services are actually received and would be paid for by an independent company).

6. Tested party and comparables search

6.1 Tested party

Example: OST-VN is the tested party for CT-001 and CT-002: its functions are simpler and better documented than those of OST-NL, and independent companies with similar functions can be found.

6.2 Search strategy

Follow the local order of priority for data sources and comparables. Under Decree 255/2026/ND-CP, public and official sources come before commercial databases and tax authority data, and internal comparables come before domestic ones, which come before regional ones. Confirm the exact order in the decree text.

StepCriterionCompanies remaining (Example)
S-01Database [name], extraction date YYYY-MM-DD; industry codes for computer programming and software services; Vietnam first, then Asia-Pacific2,140
S-02Active companies with financial data for FY2023 to FY20251,180
S-03Independence: no shareholder owning 25% or more that is itself an operating group640
S-04Revenue between EUR 2m and EUR 200m310
S-05Exclude persistent losses (losses in two or more of three years)238
S-06Qualitative review of websites and annual reports: service provider for third parties, no significant own software products11 (2 Vietnam, 9 regional)

6.3 Domestic first, then regional

Example: The domestic search accepted 2 Vietnamese companies, too few to form a reliable range. The search was extended to the Asia-Pacific region (Malaysia, Thailand, the Philippines, Indonesia, India), which accepted 9 more. Country risk differences were considered and found not to require an adjustment, because the accepted companies serve export clients on similar terms.

6.4 Accept and reject matrix

Keep a full list of companies reviewed at step S-06 with the reason for each rejection (for example "own software products above 20% of revenue", "mainly hardware trading", "insufficient segment information"). Store it in the evidence index (section 12), not in the body of this file.

7. Financial indicators and arm's length range

7.1 Profit level indicator

For CT-001 the indicator is the net cost plus (NCP): operating profit as a share of total operating costs.

NCP=Operating revenue−Total operating costsTotal operating costsNCP = \frac{\text{Operating revenue} - \text{Total operating costs}}{\text{Total operating costs}}

Total operating costs include cost of services, personnel, depreciation, office and IT costs and group service charges, and exclude interest, foreign exchange results, income tax and extraordinary items. Apply the same definition to the comparables.

7.2 Comparables results

Weighted average NCP over FY2023 to FY2025 (the latest three years available at the extraction date):

Comparable IDCountryWeighted average NCP (%)
CMP-001 (Example)Vietnam4.1
CMP-002 (Example)Malaysia5.3
CMP-003 (Example)Philippines6.0
CMP-004 (Example)Thailand6.8
CMP-005 (Example)Vietnam7.4
CMP-006 (Example)India8.2
CMP-007 (Example)Indonesia9.0
CMP-008 (Example)Malaysia9.9
CMP-009 (Example)Thailand10.6
CMP-010 (Example)India12.3
CMP-011 (Example)Philippines14.8

Arithmetic mean: 94.4 / 11 = 8.58%.

7.3 Interquartile range

Two common conventions give slightly different quartiles. State which one the local rule requires; if it is silent, state the convention used and apply it consistently every year.

Linear interpolation (spreadsheet inclusive quartile convention). For nn sorted results x(1)≤⋯≤x(n)x_{(1)} \le \dots \le x_{(n)} and percentile pp, compute the position h=1+p(n−1)h = 1 + p(n - 1), take kk as the integer part of hh, and

Qp=x(k)+(h−k) (x(k+1)−x(k))Q_p = x_{(k)} + (h - k)\,\big(x_{(k+1)} - x_{(k)}\big)

With n=11n = 11:

StatisticPosition hhCalculationResult (%)
Lower quartile (25th)3.56.0 + 0.5 x (6.8 - 6.0)6.40
Median (50th)6.08.28.20
Upper quartile (75th)8.59.9 + 0.5 x (10.6 - 9.9)10.25

US regulation convention (Treas. Reg. 1.482-1(e)(2)(iii)(C)): the 25th percentile is the lowest result such that at least 25% of results are at or below it (averaged with the next result if exactly 25%), and likewise for the 75th and 50th. With 11 results, 25% of 11 is 2.75, so the 3rd result (6.0%); 75% of 11 is 8.25, so the 9th result (10.6%); 50% of 11 is 5.5, so the 6th result (8.2%).

ConventionLower quartileMedianUpper quartile
Linear interpolation (Example)6.40%8.20%10.25%
US regulation (Example)6.00%8.20%10.60%
35th to 75th percentile, linear interpolation (former Vietnamese practice) (Example)7.10% (35th)8.20%10.25%

Vietnam applies its own percentile band and adjustment point. Decree 132/2020/ND-CP used the 35th to 75th percentile, with adjustment to the median; confirm whether Decree 255/2026/ND-CP keeps this, and recompute the range on that basis before finalising the file. Example: the 35th percentile by linear interpolation is at position 1 + 0.35 x 10 = 4.5, so 6.8 + 0.5 x (7.4 - 6.8) = 7.10%.

7.4 Tested party result

ItemCT-001 development segment FY2026 (EUR thousand)
Operating revenue (service fee) (Example)116,640
Personnel costs (Example)86,400
Office and IT costs (Example)12,800
Depreciation (Example)7,300
Group service charge (CT-003) (Example)1,500
Total operating costs (Example)108,000
Operating profit (Example)8,640
NCP (Example)8.00%

Check: 86,400 + 12,800 + 7,300 + 1,500 = 108,000; 116,640 - 108,000 = 8,640; 8,640 / 108,000 = 8.00%.

The NCP of 8.00% lies inside both versions of the interquartile range (6.40% to 10.25%, and 6.00% to 10.60%) and inside the 35th to 75th percentile band (7.10% to 10.25%), slightly below the median of 8.20%.

7.5 Sensitivity

Example: Had the fee been set at cost plus 5% (fee EUR 113,400k, NCP 5.00%), the result would sit below the lower quartile under both conventions. If the tax authority adjusted to the median of 8.20%, the adjustment would be 108,000 x (8.20% - 5.00%) = EUR 3,456k of additional taxable income in Vietnam (about EUR 346k of tax at OST-VN's 10% preferential rate, before interest and penalties; check whether the incentive covers an adjustment), with a risk of double taxation unless the Netherlands grants a corresponding adjustment. This shows why the year-end true-up in TPP-002 matters.

8. Adjustments and segmentation

8.1 Segmented income statement

Line (EUR thousand)Development segment (CT-001)Resale segment (CT-002)Entity total
Revenue (Example)116,64015,000131,640
Cost of goods sold (purchases from OST-NL, CT-002) (Example)0(12,000)(12,000)
Operating costs (Example)(108,000)(2,250)(110,250)
Operating profit (Example)8,6407509,390
Indicator (Example)NCP 8.00%Operating margin 5.00%

Check: 15,000 - 12,000 - 2,250 = 750; 750 / 15,000 = 5.00%; 8,640 + 750 = 9,390; 131,640 - 12,000 - 110,250 = 9,390.

Allocation keys: personnel by time records; office costs by floor space; group service charge to the development segment because the services support the engineering workforce. Example: The resale segment was tested against a separate set of independent distributors of electronic equipment (interquartile range 2.6% to 5.4%, median 3.9% Example); its operating margin of 5.00% is inside the range.

8.2 Comparability adjustments

AdjustmentApplied?Reason
Working capital adjustment (Example)NoReceivable days of OST-VN (61) are close to the comparables' median (58); the effect is immaterial
Capacity utilisation (Example)NoNo idle capacity in FY2026
Accounting consistency (Example)YesReclassified foreign exchange results out of operating profit for three comparables

8.3 Year-end adjustments

Example: Monthly invoices in FY2026 were based on budgeted costs of EUR 105,000k plus 8% (EUR 113,400k). Actual costs were EUR 108,000k, so a true-up invoice of EUR 3,240k was raised in December 2026: 108,000 x 1.08 = 116,640; 116,640 - 113,400 = 3,240. Record the invoice date and confirm that it was booked in the same financial year and in both entities.

9. Conclusion

Transaction IDMethodTested resultRangeConclusion
CT-001 (Example)TNMM, NCP8.00%6.40% to 10.25%Within the arm's length range
CT-002 (Example)TNMM, operating margin5.00%2.6% to 5.4%Within the arm's length range
CT-003 (Example)Cost plus 5% (provider file)Benefit test metNot applicableCharge accepted as arm's length

Example: Based on the analysis above, the controlled transactions of Ostrander Vietnam Co., Ltd in FY2026 are consistent with the arm's length principle, and no adjustment to taxable income is required.

10. APAs, rulings and disputes

ItemStatus (Example)
Unilateral or bilateral APA covering OST-VNNone
Rulings from other jurisdictions affecting these transactionsNone
Open audits or adjustmentsNone; last transfer pricing audit closed for FY2023 without adjustment
Mutual agreement procedure casesNone

11. Cross-reference to OECD Annex II and local rules

11.1 OECD Annex II items

ItemOECD Annex II headingSection
LF-01Local entity: management structure, organisation chart, reporting lines2.1
LF-02Local entity: business and strategy, restructurings, intangible transfers2.2, 2.3
LF-03Local entity: key competitors2.4
LF-04Controlled transactions: description, amounts, counterparties3.1
LF-05Copies of intercompany agreements3.2
LF-06Comparability and functional analysis4
LF-07Method selection and reasons5
LF-08Tested party6.1
LF-09Summary of assumptions4.4, 7.1
LF-10Reasons for multi-year analysis7.2
LF-11Comparables list and search6.2 to 6.4, 7.2
LF-12Comparability adjustments8.2
LF-13Reasons for arm's length conclusion9
LF-14Financial information used to apply the method7.4, 8.1
LF-15APAs and rulings10
LF-16Annual local accounts and reconciliation to financial statements8.1, 12

11.2 US principal documents (Treas. Reg. 1.6662-6(d)(2)(iii)(B))

Use this table when the entity, or a US counterparty, relies on the file for penalty protection.

No.Principal document (short title)Section
1Overview of the business2.2; master file 3
2Organisational structure2.1; master file 2
3Documentation required by the section 482 regulations3 to 8
4Method selected and why5
5Alternative methods considered and why rejected5
6Controlled transactions and internal data3, 7.4
7Comparables and adjustments6, 7.2, 8.2
8Economic analysis and projections relied on7, 8
9Relevant data obtained after year end and before filing12
10Index of documents and record-keeping system12

11.3 Local add-ons

JurisdictionAdd-on (as of 2026-10)Where answered
VietnamRelated-party transaction disclosure form filed with the corporate income tax finalisation return (confirm the form under Decree 255/2026/ND-CP); data source priority; percentile band3.1, 6.2, 7.3
GermanyTransaction matrix (section 90(3) AO); records of extraordinary transactions prepared promptlySeparate matrix appendix for German entities
United KingdomOECD format local file for in-scope groupsThis file
[Other][Item][Section]

12. Review log and evidence index

Evidence IDDocumentLocationOwner
EVD-001 (Example)Signed agreements AGR-001, AGR-003, AGR-004[Contract repository path][@legal]
EVD-002 (Example)Database extraction file and accept or reject matrix[Path][@tp-manager]
EVD-003 (Example)Segmented trial balance FY2026 reconciled to statutory accounts[Path][@finance-manager]
EVD-004 (Example)True-up invoice and posting[Path][@finance-manager]
EVD-005 (Example)Interview notes with the CTO and general director[Path][@tp-manager]
Review dateReviewerScopeOutcome
YYYY-MM-DD[@head-of-tax]Full file[Approved with comments]

Post-year-end data: record events after year end and before filing that affect the analysis (for example a comparable acquired by a group, which removes its independence). Example: None identified.

13. Glossary and references

13.1 Glossary

TermMeaning
Arm's length rangeThe range of results from comparable independent transactions considered acceptable
ComparableAn independent company or transaction whose conditions are sufficiently similar to the tested transaction
Interquartile rangeThe range from the 25th to the 75th percentile of the comparables' results
NCPNet cost plus: operating profit divided by total operating costs
Operating marginOperating profit divided by net sales
SegmentationSplitting an entity's results by transaction category so each is tested separately
TNMMTransactional net margin method
True-upYear-end adjustment that brings the actual result to the policy target

13.2 References

ReferenceVersion or date checkedUse
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations2022 edition, checked 2026-10-25Chapter I risk framework, Chapter II methods, Chapter III comparability, Chapter V Annex II structure
Vietnam Decree 255/2026/ND-CPEffective 2026-07-01Exemption test, data source and comparable priority
Germany section 90 AO and GAufzVChecked 2026-10-25Transaction matrix, deadlines
UK SI 2023/818As madeScope for UK entities
US Treas. Reg. 1.6662-6 and 1.482-1(e)eCFR text checked 2026-10-25Principal documents; interquartile range convention

Standard and licence note

Structure aligned with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, Chapter V, Annex II (OECD, used for structure and references only under the OECD terms and conditions; OECD material published from 2024-07-01 is available under CC BY 4.0). This is an adaptation in original wording; it does not represent the official views of the OECD or its Member countries. The jurisdiction rows and the US interquartile convention are based on public law: Vietnam Decree 255/2026/ND-CP, German section 90 AO with the GAufzV, UK SI 2023/818 (Open Government Licence v3.0) and US Treas. Reg. 1.6662-6 and 1.482-1 (US public domain), paraphrased in original words. Ostrander Group N.V., its subsidiaries, the comparables and every figure are fictional. This template is original text written for this collection. Check the current official versions of the guidelines and each local law before use. Template licence: MIT.

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