Taxpayers are required to provide information related to the nature and extent of commercial or financial transactions with foreign persons and PEs along with the tax return.
The TP rules require a taxpayer to prepare and maintain a written TP documentation detailing the determination of prices and terms of significant transactions between related parties. The TP documentation is required to be maintained for a period of 5 years from the end of the tax year to which the transaction relates to.
The TP documentation is required to be provided to the tax authorities within 60 days on a request made by them.
Failure to maintain proper TP documentation attracts a minimum penalty of twice the amount of expenses saved (e.g., internal staff costs and fees to tax advisors) by non-preparation of TP documentation.
Additionally, adjustment/ increase in the income if the arm's-length principle is not met, attracts the minimum penalty to be increased by an amount corresponding to 10% of such increase.
Greenland has till date not introduced a Country-by-Country reporting requirement. However, Greenland has joined the OECD’s Inclusive Framework, membership of which presupposes a commitment to implement the BEPS minimum standards, including Country-by-Country reporting.