Germany has introduced comprehensive legislation on documentation requirements with regard to international transfer pricing arrangements of multinational enterprises. This has initiated a discussion whether also in Austria such legislation should be developed. However, before an introduction of such new legislation is contemplated it seems to be important that taxpayers are encouraged fully to comply with the existing legal documentation requirements whose scope has to be interpreted on the basis of the OECD Transfer Pricing Guidelines. Furthermore, the imposition of rigid documentation requirements only on cross-border transactions could create conflicts with Community law which can not happen if domestic general documentation requirements are applicable both to domestic and international transactions and if their interpretation is based on the OECD Transfer Pricing Guidelines, where appropriate.