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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

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Maintaining progress, tackling delay

This chapter analyses the principal causes of delay in transfer pricing audits and enquiries and how they can be overcome. It discusses the process of document examination and how large volumes of material can best be managed. The chapter includes a discussion of the importance of good communication between tax administrations and taxpayers and the role of advisors. It also considers what use can be made of alternative dispute resolution techniques.

English

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