1. Canada
<Monetary threshold for LF preparation>
-
Not applicable
<Preparation deadline>
-
By the due date for filing the company’s tax return, which is within 6 months after the end of the fiscal year.
-
Reference: Subsection 247(1) of the Income Tax Act
-
<Submission deadline>
-
Within 3 months of a request by the tax authority.
-
Reference: Transfer Pricing Memorandum 05R2
-
<Language>
-
English or French.
<Penalty>
-
A penalty of 10% of the transfer pricing adjustment may be imposed.
-
Reference: Subsection 247(3) of the Income Tax Act
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2. Mexico
<Monetary threshold for LF preparation>
Applicable if any of the following conditions are met:
-
Revenue in the immediately preceding fiscal year exceeded MXN 13 million; or
-
Income from professional services exceeded MXN 3 million
<Preparation deadline>
-
By May 15th of the following fiscal year to complete Annex 9 of the DIM.
<Submission deadline>
-
By May 15th of the following fiscal year, in line with the submission deadline for Annex 9 of the DIM.
<Language>
-
Spanish
<Penalty>
-
A penalty ranging from MXN 199,630 to MXN 284,220 may be imposed for failure to submit LF.
-
Additional consequences may include disqualification from government contracts, revocation of the importer’s registry, and denial of deductions for cross-border payments.
-
Reference : Artículo 76, fracción XII – LISR (Spanish) , Artículo 76‑A (Spanish)
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3. United Kingdom
<Monetary threshold for LF preparation>
-
Not applicable
<Preparation deadline>
-
By the due date for filing the company’s tax return, which is 12 months after the end of the accounting period.
<Submission deadline>
-
Typically, within 30 days of a request by the tax authority.
-
Reference: INTM450050
-
<Language>
-
English
<Penalty>
-
If LF is not submitted within 30 days of a request, an initial penalty of GBP 300 may be imposed, followed by a daily penalty of GBP 60 for each day the failure continues.
-
Reference: INTM450050
-
4. China
<Monetary threshold for LF preparation>
Applicable if related-party transactions exceed any of the following thresholds during the fiscal year:
-
RMB 200 million for tangible asset transfer
-
RMB 100 million for financial asset transfer
-
RMB 100 million for intangible asset transfer
-
RMB 40 million for other related-party transactions
<Preparation deadline>
-
By June 30 of the year following the year in which the related-party transactions occurred.
<Submission deadline>
-
Within 3 months of a request by the tax authority.
<Language>
<Penalty>
-
A 5% interest surcharge may be imposed in addition to any underpaid tax resulting from a transfer pricing adjustment.
5. India
<Monetary threshold for LF preparation>
-
Applicable if aggregate international transactions exceed INR 10 million during the fiscal year.
-
Reference: Section 10D(2) in Income Tax Rules, 1962
-
<Preparation deadline>
-
By October 31 following the end of the financial year.
-
Reference: Section 10D(4) in Income Tax Rules, 1962
-
<Submission deadline>
-
Upon request by the tax authority.
<Language>
-
English
<Penalty>
-
A penalty of 2% of the value of each international transaction may be imposed for failure to maintain LF.
-
Reference: Section 271G in Income Tax Rules, 1962
-
6. Japan
<Monetary threshold for LF preparation>
Applicable if, in the previous fiscal year, transactions with a single foreign-related party were either:
-
JPY 5 billion or more (excluding intangible assets), or
-
JPY 300 million or more (intangible assets only)
<Preparation deadline>
-
By the due date for filing the final tax return, which is within 2 months after the end of the fiscal year.
<Submission deadline>
-
By the date specified by the tax authority (typically within 45 or 60 days of a request).
<Language>
-
No specific language is required, but a Japanese translation may be requested by the tax authority.
<Penalty>
-
The tax authority may determine taxable income based on estimated arm’s length prices using undisclosed comparables.
7. Germany
<Monetary threshold for LF preparation>
Applicable if related-party transactions exceed any of the following thresholds:
-
EUR 6 million for tangible (inventory) transactions
-
EUR 600,000 for non-inventory (e.g., services, royalties) transactions
<Preparation deadline>
-
Thers is no explicit statutory deadline. However, contemporaneous documentations must be prepared for extraordinary business transactions within 6 months after the end of the fiscal year.
<Submission deadline>
-
Within 30 days of a request by the tax authority.
<Language>
-
German is required, but English may also be accepted.
<Penalty>
-
A penalty ranging from 5% to 10% of the additional income from a correction may be imposed, with a minimum of EUR 5,000.
-
Failure to submit LF on time may result in a penalty of up to EUR 1,000,000, with a minimum of EUR 100 per full day of delay.
8. Australia
<Monetary threshold for LF preparation>
Applicable if the entity is a member of a multinational enterprise (MNE) group with consolidated revenue of AUD 1 billion
or more.
<Preparation deadline>
-
Within 15 days after the end of the 7th month following the fiscal year-end.
<Submission deadline>
-
Within 12 months after the end of the fiscal year.
<Language>
-
English
<Penalty>
-
Failure to submit LF may result in significant penalties, up to AUD 825,000.
-
Reference: Subdivision 815-E of the ITAA 1997
-
9. France
<Monetary threshold for LF preparation>
Applicable if any of the following conditions are met:
-
Annual revenue or total assets of EUR 150 million or more
-
Direct or indirect ownership of more than 50% of an entity meeting the above threshold
-
Direct or indirect ownership by an entity meeting the above threshold
-
Membership in a French tax-consolidated group that includes at least one such entity
<Preparation deadline>
-
By the due date for filing the company’s corporate income tax return.
-
If the fiscal year-end is December 31, the filing deadline is in early May.
-
For other fiscal year-ends, the deadline is generally 3 months after the end of the fiscal year.
<Submission deadline>
-
Within 30 days of a request by the tax authority (an extension up to 60 days may be granted).
<Language>
-
French（A French translation may be requested if the LF is prepared in English）
<Penalty>
-
A penalty may be imposed equal to the greater of 5% of the additional tax assessed, 0.5% of the amount of intercompany transactions, or EUR 50,000 per audited fiscal year.
-
Reference: Article L13 AB du LPF (French)
-
Reference: BOI-BIC-BASE-80-10-40 (French)
-
10. Brazil
<Monetary threshold for LF preparation>
Applicable if the total amount of cross-border related-party transactions (before transfer pricing adjustments) is:
-
Over BRL 500 million: Full Local File
-
Between BRL 15 million and BRL 500 million: Simplified Local File
-
Less than BRL 15 million: No documentation required (but explanation required upon request)
<Preparation deadline>
-
By the due date for filing the company’s corporate income tax return.
<Submission deadline>
-
Within 3 months of the deadline for filing the corporate income tax return via the e-CAC system.
<Language>
-
Portuguese
<Penalty>
-
A penalty of 0.2% of the taxpayer’s gross income per month (or part thereof) may be imposed for failure to submit LF.
-
Failure to meet LF standards may result in an additional penalty of 3% of gross income for the relevant period.
-
Reference: Normative Instruction Nº 2161 (Portuguese)
-
11. Ireland
<Monetary threshold for LF preparation>
-
Applicable if the entity is a member of an MNE group with consolidated revenue of EUR 50 million or more in the chargeable period.
<Preparation deadline>
-
By the due date for filing the company’s tax return, which is typically 9 months after the end of the chargeable period.
<Submission deadline>
-
Within 30 days of a request by the tax authority.
<Language>
-
English or Irish
<Penalty>
-
Failure to submit LF may result in penalties of up to EUR 25,000 plus EUR 100 for each day the failure continues.
-
Reference: Section 27 of the Finance Act 2019
-
12. Korea
<Monetary threshold for LF preparation>
Applicable only if both of the following conditions are met:
-
Related-party transactions exceed KRW 50 billion
-
Standalone Revenue exceeds KRW 100 billion
<Preparation deadline>
-
By the LF submission deadline (same as the preparation deadline).
<Submission deadline>
-
Within 12 months after the end of the fiscal year.
<Language>
-
Korean
<Penalty>
-
Failure to submit, or submission of false information, may result in a fine of KRW 30 million.
-
Reference: Article 21-2 of EDAAIT
-
Reference: Article 16 of AAIT
-
13. Netherlands
<Monetary threshold for LF preparation>
-
Applicable if the entity is a member of an MNE group with consolidated revenue of EUR 50 million or more.
<Preparation deadline>
-
Within 5 months after the end of the fiscal year.
<Submission deadline>
-
Upon request by the tax authority.
<Language>
-
English or Dutch
<Penalty>
-
Failure to comply may result in a fine of up to EUR 10,300 or imprisonment for up to 6 months.
-
In cases of intentional non-compliance, the penalty may increase to EUR 25,750 or imprisonment for up to 4 years.
-
Reference: Article 29g of the DCIT (Dutch)
-
14. Singapore
<Monetary threshold for LF preparation>
Applicable if gross revenue exceeds SGD 10 million, and related-party transactions exceed the following thresholds:
-
SGD 15 million for purchase or sale of goods
-
SGD 15 million for loans
-
SGD 1 million per category for other transactions (e.g., services, royalties, leases, guarantees)
<Preparation deadline>
-
By the due date for filing the company’s tax return (i.e., 11 months after the end of the fiscal year).
<Submission deadline>
-
Within 30 days of a request by the tax authority.
<Language>
-
English
<Penalty>
-
Failure to prepare, submit, or ensure the accuracy of LF may result in a fine of up to SGD 10,000.
-
In addition, a 5% surcharge may be imposed on the amount of any transfer pricing adjustment.
-
Reference: Section 34F of the Income Tax Act 1947
-
Reference: Income Tax RULES 2018
-
15. Italy
<Monetary threshold for LF preparation>
-
Not applicable
<Preparation deadline>
-
By the due date for filing the company’s tax return, which is 10 months after the end of the tax year.
<Submission deadline>
-
Within 20 days of a request by the tax authority.
<Language>
-
Italian
<Penalty>
-
If proper LF is not available, penalties generally range from 50% to 100% of the additional tax assessed.
-
Reference: Implementation guidance on TP documentation (Italian)
-
16. Switzerland
<Monetary threshold for LF preparation>
-
Not applicable
<Preparation deadline>
-
Not applicable
<Submission deadline>
-
Negotiable
<Language>
-
Local language or English
<Penalty>
-
No specific penalties apply. However, failure to act in good faith may lead to challenges during a tax audit.
17. Thailand
<Monetary threshold for LF preparation>
-
Applicable if annual revenue is THB 200 million or more.
-
Transfer pricing disclosure form on related party transactions must be submitted with corporate income tax return.
-
Local file must be submitted upon request from the Thai Revenue Department.
<Preparation deadline>
-
Not applicable
<Submission deadline>
-
Within 60 days of a request by the tax authority (or within 180 days for the first request).
<Language>
-
Thai language
<Penalty>
-
A fine not exceeding THB 200,000 may be imposed for non-compliance.
-
Reference: Section 71 Bis and Section 71 Ter（Thai language）
-
18. Malaysia
<Monetary threshold for LF preparation>
Applicable if any of the following criteria are met:
-
Gross income exceeds MYR 30 million and the value of cross-border controlled transactions exceeds MYR 10 million.
-
Financial assistance exceeds MYR 50 million.
<Preparation deadline>
-
Within 7 months after the end of the fiscal year.
<Submission deadline>
-
Within 14 days of a request by the tax authority.
<Language>
-
Bahasa Malaysia or English.
<Penalty>
-
A penalty ranging from RM20,000 to RM100,000 may be imposed for each year of assessment in which LF is not submitted on time.
-
Reference: Malaysia Transfer Pricing Guidelines 2024
-
19. Indonesia
<Monetary threshold for LF preparation>
Applicable if any of the following thresholds are met:
-
Annual gross revenue is IDR 50 billion or more
-
Related-party transactions involving tangible goods totaling IDR 20 billion or more
-
Related-party transactions involving services, intangible assets, or other transactions totaling IDR 5 billion or more
-
Transactions with related parties located in countries with lower tax rates than Indonesia
<Preparation deadline>
-
Within 4 months after the end of the fiscal year.
<Submission deadline>
-
Within 1 month of a request by the tax authority.
<Language>
-
Indonesian
<Penalty>
-
PMK-172/2023 does not stipulate specific monetary penalties.
-
However, failure to submit LF upon request may lead to adjustments based on the tax authority’s own transfer pricing analysis.
-
Reference: PMK 172/2023
-
20. Vietnam
<Monetary threshold for LF preparation>
Applicable if none of the following exemption criteria are met:
-
Revenue is less than VND 50 billion and related-party transaction value is less than VND 30 billion.
-
The taxpayer is covered by an APA and has submitted the annual report.
-
The taxpayer performs only routine functions, has no income or expenses from the use of intangible assets, has total revenue of less than VND 200 billion, and has EBIT margins of at least 5% for distribution, 10% for manufacturing, and 15% for processing.
<Preparation deadline>
-
Within 90 days from the end of the fiscal year (i.e., the corporate income tax return filing deadline).
<Submission deadline>
-
Within 30 days of a request by the tax authority.
<Language>
-
Vietnamese
<Penalty>
-
Vietnam imposes penalties for transfer pricing non-compliance, including fines of VND 8–15 million for missing TP forms, a 20% penalty on underpaid tax due to incorrect declarations, daily interest of 0.03% on late payments, and up to three times the unpaid tax for tax evasion.
-
Reference: Decree No. 132/2020/ND-CP（Vietnamese）
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