With Transfer Pricing at a Turning Point Taxand Launches New Guide
With transfer pricing at a turning point, Taxand, the world's largest global organisation of tax advisors to multinational businesses, today celebrates the launch of this year's Taxand / IBFD Global Guide to Transfer Pricing published by IBFD and incorporating the official text of the latest OECD Transfer Pricing Guidelines.
Historically, transfer pricing constitutes an area of misunderstanding between multinational enterprises (MNEs) and tax authorities. From the outset there has been a clear lack of rules from tax authorities across the world and a lack of transparency from global companies. Uncertainty had led to rather erratic practices, largely dictated by the operational constraints of MNEs, or the weight of their history with which tax rationality had only little to do.
However, over the past few years these initial trends have been obscured due to: the emergence of the OECD guidelines that have largely been taken up by the major global players; the employment of more expert practitioners within MNEs, advisors and governments; and, stricter and more accurate documentation obligations
Today the discipline is at a turning point that all constituents must learn to negotiate. Going forward through better business understanding and less focus on the need to reduce public debt, the myopic aggressiveness of governments across the globe must make way for a more selective approach to investigations. The, often unintentional, absence of judges in this debate must yield ground to an increased role for referees and regulators to clarify areas of uncertainty and reduce disputes. A clear, technical framework must be in place. Global companies must be less afraid of using fair inter-company transfer pricing to reduce the risk of double taxation.
Antoine Glaize, Global Transfer Pricing Leader at Taxand, added: "In the past the aggressive position of tax authorities has paralysed MNEs' activity and slowed down operations, restricting development and growth.
"Whilst progress has been made, international companies still encounter too many situations in major jurisdictions where their legal safety is not sufficiently assured at the price of double taxation.
"Keeping up to date with transfer pricing regulatory change worldwide is a big challenge for all multinationals while effective and secured international transfer pricing policy is essential. Taxand's collaboration with the IBFD to produce our annual guide to transfer pricing gives multinationals easy access to the latest OECD guidelines and an overview of the current transfer pricing laws, guidelines and methodologies in practice in each of the 33 countries covered. We believe it will go some way in helping our clients negotiate the turning point at which transfer pricing finds itself today."
Taxand Global Marketing
T. +44 207 715 5243