PER-29 does not specifically stipulate any kind of penalties that will be imposed should Taxpayers fail to fulfil the CbCR requirements.  However, PMK-213 stipulates that in the event that a Taxpayer fails to prepare CbCR based on the data available at the end of the related fiscal year, the Taxpayer shall be deemed as not applying the arm’s length principle.

Further, it is also anticipated that there may be potential penalties on any unpaid tax of up to 50% due to incomplete CITR submission.