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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Transfer pricing and developing countries
chapter is concerned with the challenges developing countries face in the field of transfer pricing. It considers some of the ways in which those challenges can be overcome and the part international co-operation has to play. It also looks at ways in which access to information and comparables could be improved in developing countries.
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