Guide pratique pour assurer votre défense en matière de prix de transfert
 
Guide pratique pour assurer votre défense en matière de prix de transfert

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.
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.