Transfer Pricing
Taxand Americas Guide to Transfer Pricing 2013
Taxand / IBFD 2012 Global Guide to Transfer Pricing
Taxand 2010 Global Guide to APAs & CAs
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Taxand Americas Guide to Transfer Pricing 2013
In addition to our Taxand/IBFD Global Guide to Transfer Pricing 2012, our Americas team have produced the Taxand Americas Guide to Transfer Pricing.
Nowhere has transfer pricing regulation complexity increased further in recent years than in the Americas, as companies continue to investigate more cost effective operational footprints.
With the global economy continuing to put pressure on existing transfer pricing models, multinationals are looking for ways to improve their corporate structures to achieve efficiencies. Keeping up with ever-changing transfer pricing legislation is challenging. Coupled with the launch of the substantially revised OECD 2010 transfer pricing guidelines and tax authorities ratcheting up their audit programs, keeping abreast of change and the associated risk of non-compliance, can be difficult.
That’s why we have launched the second issue of our Taxand Americas Guide to Transfer Pricing, an essential desktop ‘ready reference’ for corporate executives seeking to understand the transfer pricing rules applicable to the Americas.
Covering: – by country; – documentation requirements, applicable transfer pricing methods, related party definitions, penalties for non-compliance and thin capitalisation rules, this publication guides you through the key rules to inform your decision making.
Taxand’s Take
- consider transfer pricing obligations in countries where you are or intend to do business in
- identify where operations are expanding and contracting and use this change to get the pricing correct
- consider the likely impact of the OECD 2010 transfer pricing guideline revisions.
Request your Taxand Americas Guide to Transfer Pricing 2013 here
Find out more about our Transfer Pricing services here
To discuss your transfer pricing requirements in depth contact your nearest Taxand transfer pricing specialist here
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Taxand / IBFD 2012 Global Guide to Transfer Pricing
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and Transfer Pricing Features of Selected Countries 2012
Taxand has collaborated with the IBFD to produce an essential desk top “ready reference” guide to transfer pricing worldwide.
Today, transfer pricing is one of the most important issues facing MNCs as they attempt to fairly distribute their profits amongst each company in the group while dealing with tax authorities who are implementing transfer pricing regulations and strengthening enforcement in order to prevent a loss of revenue. The result of which is that transfer pricing controversies have become a major tax issue for companies.
Our Taxand / IBFD Global Guide to Transfer Pricing 2012 brings you:
- overview of the current transfer pricing laws
- guidelines and methodologies in practice
- standardised chapters, with quick and easy comparisons
- insight from 35 countries, globally
- the official text of 2010 OECD Transfer Pricing Guidelines
The role of MNCs in world trade has increased dramatically over the last 20 years. The growth of MNCs presents increasingly complex taxation issues for both tax administrations and the MNCs themselves, since separate country rules for the taxation of MNCs cannot be viewed in isolation but must be addressed in a broad international context.
That's why Taxand has collaborated with the IBFD to produce this guide. Key TP information has been provided and assessed by Taxand TP practitioners and IBFD professionals experienced in working with multinationals. These global practitioners, present their domestic expertise, in an international context.
Taxand's Take
As our Taxand Global Survey 2012 revealed, despite a sharp rise in transfer pricing regulation enforcement, multinationals are becoming more familiar with compliance demands and developing stronger relationships with tax authorities. Despite that, inter-country trade and investment is on the rise for many multinationals. Improved coordination between countries is therefore key. Minimising conflict and ensuring cooperating across borders is as important as ever. Transfer pricing remains one of the most important issues facing our clients today. Now more than ever multinationals must act.
When dealing with ever-changing country tax legislation, increased complexity and the risk of double taxation, multinationals should be prepared to:
- Use effective transfer pricing planning to reduce the increasing costs and burden of compliance
- Adopt the arm’s length principle and a separate entity approach in OECD countries to promote cross-border transactions
- Avoid costly litigation by finding mutually satisfactory solutions to transfer pricing issues
- Consider all aspects of transfer pricing, including the fair allocation of the burden of proof, to achieve a balance between taxpayers and tax administrations interests
Antoine Glaize, Global Transfer Pricing Leader at Taxand, commented: “Across much of the globe we are seeing harmonised systems with consistent approaches to transfer pricing principles in place. Despite this, we still have a few select countries working to slightly different rules and practices, and others that have some catching up to do in terms of enforcement; this is most notable in emerging markets, especially in Asia, where the transfer pricing knowledge base is relatively low amongst the tax authorities.
“Multinationals are continually increasing their knowledge and understanding of the complexities of transfer pricing principles globally. However, the rising levels of authorities scrutinising financial transactions from a transfer pricing standpoint is starting to cause some concern amongst multinationals. We hope that the Taxand IBFD global guide to transfer pricing is an essential reference for multinationals.”
Use this guide as a reference tool to get you started. Then consider seeking advice to approach transfer pricing not merely as a matter of risk management but also as a highly effective international tax planning tool, taking all areas of taxation into account.
Find your local Taxand transfer pricing advisor here
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Taxand / IBFD 2011 Global Guide to Transfer Pricing
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and Transfer Pricing Features of Selected Countries 2011
Taxand has collaborated with the IBFD to produce an essential desk top “ready reference” guide to transfer pricing worldwide.
Amidst the continuing instability within the global economy, the delicate balance between the interests of multinational companies and the tax authorities is as important as ever. Transfer pricing is crucial to maintaining this balance and now a major tax issue for multinationals seeking to maximise tax efficiencies and limit double taxation. Keeping up to speed with all of this change is a challenge.
Our Taxand / IBFD Global Guide to Transfer Pricing 2011 brings you:
- overview of the current transfer pricing laws
- guidelines and methodologies in practice
- standardised chapters, with quick and easy comparisons
- insight from 35 countries, globally
- the official text of 2010 OECD Transfer Pricing Guidelines
The role of multinationals in world trade continues to increase, as do the complexities associated with managing their operations across multiple jurisdictions. Frequent legislative change and the differing regimes of jurisdictions, continue to increase the burden of compliance for multinationals. Yet economies across the globe need to stimulate multinationals’ investment and trade activities to encourage upturn. The use of effective Transfer Pricing planning and the clarification of Transfer Pricing rules is becoming more and more important.
That's why Taxand has collaborated with the IBFD to produce this guide. Key transfer pricing information has been provided and assessed by Taxand transfer pricing practitioners and IBFD professionals used to working with multinationals. The content therefore presents a domestic as well as an international context. By standardising the structure of the chapters, quick and easy comparisons between countries can be made.
Taxand's Take
Taxand transfer pricing specialists believe in this environment it is essential that tax authorities worldwide cooperate to ensure that the taxation of multinationals and the implementation of transfer pricing rules is not viewed in domestic isolation but is addressed in a broad international context.
"In a global economy, the coordination of tax policy amongst countries serves as the best approach in securing the objectives of both tax authorities and multinationals. Within an area as complex as transfer pricing, it is imperative that the international principles chosen by OECD member countries serve the dual objectives of securing appropriate tax bases and avoiding double taxation, thereby minimising conflicts." Antoine Glaize, Taxand Global Transfer Pricing Service Line Leader
Use this guide as a reference tool to get you started. Then consider seeking advice to approach transfer pricing not merely as a matter of risk management but also as a highly effective international tax planning tool, taking all areas of taxation into account.
Find your local Taxand transfer pricing advisor here
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Taxand Global Guide to APAs & CAs
As tax authorities worldwide seek to increase tax takes to beat the downturn, multinationals face further scrutiny. Whether planning a complex transaction or reassessing your transfer pricing position, understanding Advance Pricing Agreement programmes and Competent Authority procedures is essential.
Taxand's Global Guide to APAs and CAs - split by region -provides you with an at-a-glance view of the key legislation in place. Take a look to inform your risk management strategy. You can save time and money, plan against audits and prevent double taxation if you're in the know.
Download here:
Taxand's Take
Multinationals are today staring at a decade of scrutiny, with cross-border transactions being seen as the low hanging fruit for tax authorities around the world. We encourage you to consider using APAs to negotiate agreements with tax authorities in advance of your most complex transactions. Where tax audit enquiries are already inevitable, we urge you to leverage Competent Authorities procedures (CAs) to limit the impact of a re-assessment.
Taxand's global guide is designed to help you get a feel for the legislation in place surrounding APAs and CAs. Use this guide as a reference tool to get you started. Then consider your position and seek advice. Otherwise you risk, not only paying too much tax or worse still, double taxation, but also a time-consuming and potentially expensive audit down the line.
Find out more about our transfer pricing services here.
To discuss your transfer pricing requirements in depth contact your nearest Taxand transfer pricing specialist here.
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Taxand Americas Guide to Transfer Pricing - Request now!
As the economic downturn puts pressure on existing transfer pricing models, companies are seeking to revise their corporate structures to achieve efficiencies. With governments regularly amending legislation, the OECD guidelines widening by the year and tax authorities ratcheting up their audit programmes, keeping abreast of change and the associated risk of non-compliance, can be difficult. Nowhere has transfer pricing regulation complexity increased further in recent years than in the Americas. So what better time to produce a book dedicated to helping you understand the transfer pricing rules applicable to the Americas? Designed as an essential desk top "ready reference" for corporate executives, Taxand's publication guides you through the key rules to inform your decision-making, covering an overview of the OECD guidelines and - by country - documentation requirements; applicable transfer pricing methods; related party definitions; penalties for non-compliance and thin capitalisation rules. Taxand's Take Taxand recommends where you have or are considering operations in the Americas that you always bear in mind the transfer pricing implications of your corporate structure alongside the business issues you face. Efficiencies can be achieved and risk diverted if you apply the optimum transfer pricing policy. Request your Taxand Americas Guide to Transfer Pricing here. Taxand's global transfer pricing team brings together specialists to help clients meet their transfer pricing obligations while achieving meaningful tax efficiencies. Made up of multi-jurisdictional and local experts who understand in depth the transfer pricing regulations and administrative practices at work worldwide, Taxand delivers high quality, proactive advice. Taxand's independence ensures freedom from audit-based conflicts of interest and the delivery of a responsive service. Find out more about our transfer pricing services here. To discuss your transfer pricing requirements in depth contact your nearest Taxand transfer pricing specialist here. PUBLICATIONS CONTACT
In addition to our global guide to transfer pricing prepared with the IBFD, our Americas team have produced the Taxand Americas Guide to Transfer Pricing.
Lynne Sandland
Taxand Global Head of Marketing
T. +44 (0)20 7072 3251
E. lsandland@taxand.com