On whom is the burden of proof to prove the results of transactions?
Transfer Pricing documentation should allow the FTA to ascertain that the tax outcome of the Tax Period has been affected by transfer pricing practices that are not in line with the ALP. The burden of proof falls on the Taxable Person to maintain sufficient supporting documentation as well as to make timely submissions to the FTA in order to support the position taken in the tax return as it relates to the controlled transactions that are in scope for each Tax Period.
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