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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.Click to Access:
- 19 Jan 2012
Resources, skills and use of specialists
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Transfer pricing work is a specialism in its own right and complex cases will often require input from experts in other specialist fields as well. This chapter discusses how tax administrations can best manage and develop the skills and knowledge needed to run effective transfer pricing programmes. It also looks at ways in which the work can be organised.