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Transfer pricing documentation: contemporaneous records required and rapid furnishing on demand to enhance transparency and enforcement.
Clause 171 mandates maintenance and furnishing of prescribed transfer pricing documentation by persons entering into international or specified domestic transactions and by constituent entities of international groups, while delegating the specific content, retention periods, thresholds and filing procedures to rules. It enshrines a ten day furnishing requirement with possible extension, cross references definitions to the Bill's reporting provisions, and anticipates master file, local file and country by country reporting formats, thereby consolidating and modernising existing documentary obligations.