(a) local entity structure including its management structure of the local entity, a local organization chart and a description of the individuals to whom local management reports and the country or countries in which such individuals maintain their principal offices;
(b) a detailed description of the business and business strategy pursued by the local entity including an indication whether the local entity has been involved in or affected by business restructurings or intangibles transfers in the present or immediately past year and an explanation of those aspects of such transactions affecting the local entity;
(c) key competitors;
(d) information for each category of controlled transactions in which the taxpayer is involved, including -
(i) a description of all the controlled transactions (e.g. procurement of manufacturing services, purchase of goods, provision of services, loans, financial and performance guarantees, licences of intangibles, etc.) and the context in which such transactions take place;
(ii) the amount of intra-group payments and receipts for each category of controlled transactions involving the local entity (i.e. payments and receipts for products, services, royalties, interest, etc.) broken down by tax jurisdiction of the foreign payer or recipient;
(iii) an identification of associated enterprises involved in each category of controlled transactions and the relationship amongst them;
(iv) detailed list of all inter-company agreements and copies of all such agreements concluded by the taxpayer;
(v) a detailed comparability and functional analysis of the taxpayer and relevant associated enterprises with respect to each documented category of controlled transactions, including any changes compared to prior three years;
(vi) an indication of the most appropriate transfer pricing method with regard to the category of transaction and the reasons for selecting that method;
(vii) detailed information on transfer pricing methods applied including comparable searches criteria, results of searches and application of transfer pricing method;
(viii) information regarding periodically updating and refreshing comparable searches and the period after which such comparable searches are updated and refreshed; and
(ix) list of all existing unilateral and bilateral or multilateral advance pricing agreements and copies thereof and other tax rulings to which Pakistan is not a party and which are related to controlled transactions described as aforesaid; and
(e) financial information including -
(i) annual local entity financial accounts for the fiscal year concerned. If audited statements exist they should be supplied and if not, existing unaudited statements should be supplied;
(ii) information and allocation schedules showing how the financial data used in applying the transfer pricing method may be tied to the annual financial statements; and
(iii) summary schedules of relevant financial data for comparables used in the analysis and the sources from which that data was obtained.
