A. A Taxable Person shall submit to the Authority together with their annual income tax declaration a Disclosure Form containing information related to such Controlled Transactions, including the following:
1. Information about Related Person or Persons party to the Controlled Transaction, including the name of such Person or Persons and the country or countries in which such Person or Persons reside and are established.
2. Information about any business restructuring for the MNE Group or the Taxable Person.
3. Information about the legal and beneficial owners of the Taxable Person, including the name of such Person or Persons and the country or countries in which such Person or Persons is/are established and reside and the percentage of ownership.
4. Total revenue, total expenses and amount of net profit or loss as reported in the annual income tax declaration for the same year.
5. Information about the type and nature of the relationship amongst the Related Persons party to the Controlled Transaction.
6. A description of the nature of the business activity or activities of the Related Persons and of the Controlled Transactions.
7. Transactional information, including aggregate amounts of consideration, nature of receipt or income or nature of payment or expenditure.
8. Transfer Pricing method applied in accordance with Chapter 4 of the Bylaws.
9. A statement certifying whether or not the Taxable Person, in the tax period to which the tax return relates, has entered into any Controlled Transaction, or any Transaction without consideration or non-monetary consideration (such as barters and trades). In the event that the Taxable Person certifies that he has entered into any or all of such Transactions, the Taxable Person shall provide the details of such Transaction or Transactions to the Authority along with the Disclosure Form that includes information on the fair market value of the consideration or barter exchange, if any.
10. Whether the Person maintains Transfer Pricing documentation as per (Chapter Eight) of the Bylaws, including the Master File and Local File.
B. Taxable Persons shall submit the Disclosure Form of Controlled Transactions to the Authority within 120 days after the last day of the fiscal year. The Authority shall specify all administrative procedures concerning the submission of the Disclosure form of Controlled Transactions in the Guidelines.
C. Together with the Disclosure Form of Controlled Transactions the Tax Payer must submit an affidavit from a licensed auditor through which the auditor certifies that the Transfer Pricing policy of the MNE is consistently applied by and in relation to the Tax Payer.
D. At its discretion, the Authority may make further inquiries with Persons engaged in or party to a Controlled Transactions through interrogatories or similar form that the Authority sets.
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