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. 



Annex E: Cloud computing

The term “cloud” has been around for a while as a simple metaphor to represent a complex information technology infrastructure. Originally used to represent the telephone network, the cloud symbol is now commonly used to represent the Internet. “Cloud computing” is a generic term for the delivery of information technology services over the Internet. Probably the most basic form of cloud computing service is the provision of data storage. The user files information over the Internet and it is stored by the third party service provider. The user no longer has to worry about backing up their data as that is part of the service and the data are generally accessible to the user wherever they are able to access the Internet. On the other hand the user generally has no interest in, and frequently no control over, where the service provider chooses to locate the servers on which their data are stored. That does not mean that this cannot be specified in any agreement with a service provider if a particular user is concerned about the location of their data.


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