If you ask a tax professional which topic is currently hot in international tax, the odds are high their answer is either “transfer pricing” or “BEPS”. In this short article, we discuss the relation between these two topics.
This article explains the difference between domestic and international transfer pricing. For understanding, we first need to look at domestic vs international controlled transactions.
The number of transfer pricing disputes is increasing. GE, Starbucks, Apple, Facebook and Nike are just a few examples of the many MNEs that are, or have been, subject to disputes around the world. Moreover, the counter-parties of these disputes are not just tax authorities, but also supranational organizations, such as the European Union. And it is not just large-listed MNEs that face scrutiny. Smaller MNEs are subjected to the same legislation after all.
This short article first discusses the nature of transfer pricing disputes. It then lists the most common dispute areas, before moving on to a few basic measures you can take to limit your risk on a transfer pricing dispute. [Read more…]
Transfer pricing has become the key focus area for tax authorities when assessing taxpayers. An explanation for this is that transfer pricing corrections are generally an easy way to drive tax proceeds. Within the industry it is observed that the number of transfer pricing “audits” increases when there is a large deficit in a government’s budget. This will of course be denied by tax authorities, but in practice, everyone knows about it.
If your firm is subject to Transfer Pricing Rules, there is a good chance that at some point you experience scrutiny on your policy. This may sound as a nightmare, and in some cases it is. However, the vast majority of transfer pricing audits do not end badly.
In this short article we provide information about transfer pricing audits, and suggestions on how you can handle these efficiently. [Read more…]
In this short article, we explain what a Country-by-Country report is, and when you need to create one. We also give an overview of what needs to be included.