Section 172

Section 172: accountant's report for international and specified domestic transactions

Section 172 is a short but important compliance requirement in the transfer pricing chapter: anyone who has entered into an international transaction or a specified domestic transaction during a tax year must get an accountant's report and file it by the specified date.

What the section requires

Every person who has entered into an international transaction or specified domestic transaction during a tax year shall obtain a report from an accountant and furnish that report on or before the specified date, in the prescribed form, duly signed and verified by the accountant in the prescribed manner, and setting out such particulars as may be prescribed.

Frequently asked questions

Who must obtain the accountant's report under Section 172?

Every person who has entered into an international transaction or a specified domestic transaction during the tax year.

By when must the report be furnished?

On or before the specified date, in the prescribed form, duly signed and verified by the accountant in the manner prescribed. ("Specified date" is defined in Section 173(d) as one month before the due date for furnishing the return of income under Section 263(1) for the relevant tax year.)