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Dealing Effectively with the Challenges of Transfer Pricing

image of Dealing Effectively with the Challenges of Transfer Pricing

This report addresses the practical administration of transfer pricing programmes by tax administrations. Technical analysis of how transfer prices should be computed in accordance with the arm’s length principle is outside the scope of this report. Instead the report focuses on the practical experiences of a number of FTA member countries and some non-member countries. The report discusses ways in which the management of transfer pricing programmes can be optimised, so that transfer pricing audits and enquiries are conducted efficiently and in a timely manner, for the benefit of MNEs and tax administrations alike. It is concerned with the practical steps tax administrations need to take to correctly identify transfer pricing cases that merit audit or enquiry and then to progress those cases to as early a conclusion as possible. 

English

Introduction

This chapter discusses the importance of transfer pricing issues and the reasons why they have tended to increase in terms of both complexity and importance. It sets out some of the administrative challenges tax administrations have to face when managing transfer pricing programmes and the purpose of the study that resulted in the report. It describes the work programme and the results of the initial survey of participating tax administrations.

English

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