Guide
pratique pour assurer votre défense en
matière de prix de transfert |
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Transfer pricing is
probably the international tax issue of the past
few years, and will continue to be in decades
to come. For a variety of reasons – not
least of which is a budgetary one, having a diversified
presence far too often means being confronted
with a patchwork of transfer pricing rules. Not
only do they swallow up huge amounts of internal
resources, but they do not necessarily reflect
what a diligent manager would need in open market
conditions to make a well-informed business decision.
In this current contribution, the writers give
an overview
of the most relevant transfer pricing rules groups
might be confronted with when acting on a global
basis. Although far from exhaustive, it does highlight
the need to put transfer pricing and transfer pricing
documentation requirements into perspective.
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| To this end, the writers herald a practical method
of addressing the multitude of transfer pricing
rules: an approach based on materiality and mirroring
a diligent-manager approach. Inspiration is also
found in a number of initiatives by, amongst others,
the OECD and the EU Joint Transfer Pricing Forum.
In addition, the current contribution explains the
procedural means available to taxpayers to avoid
double taxation in the event they might still be
subject to unilateral tax adjustments. |
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