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The state of transfer pricing documentation was fairly simple prior to the transfer pricing penalty final Regulations in 1996 ( TD 8656 , February 8, 1996). 1 While the U.S. penalty Regulations created a flurry of activity, including a veritable cottage industry of external consultants offering their own version of documentation compliance, 2 most multinational enterprises (MNEs) had developed their own documentation models, or relied on external consultants, by the late 1990s. The cost of transfer pricing documentation compliance clearly had increased from pre-1996.
By 2004, some 20 other countries had adopted their own transfer pricing penalty and related documentation regimes, each seemingly more draconian than its predecessors...
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