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12.4.2. Specific TP Issues

The domestic law of Sri Lanka does not provide any specific rules for determining the arm’s length price for transactions involving intra-group services, intangible property, and cost contribution agreements. However, taxpayers are required to disclose information of intra-group service transactions with associated enterprises under expense transactions of associated enterprises in the Transfer Pricing Disclosure Form (see Sec. 12.4.3.).

Permanent Establishment (‘AOA Approach’)

Under the Authorized OECD Approach (AOA), the OECD has published guidelines for the allocation of profits to permanent establishments. Sri Lanka does not follow the AOA approach for the attribution of profits to permanent establishments and the attribution is done in accordance with the relevant tax treaty and provisions of the domestic tax law.