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.
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Reaching a decision point
This chapter considers the closing stages of an audit or enquiry and the process of deciding the final outcome. In particular it looks at the way in which decisions to settle or litigate are reached, the process of negotiation, the role of an internal appeals function and litigation.
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