Transfer pricing perspectives:
Re:solutions moving towards certainty
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| Insights into the issues and challenges facing the emerging markets of Central Eastern Europe, India, China and Latin America: Tax offices in Central and Eastern Europe: Wind of change? Transfer pricing is rapidly evolving in Central and Eastern Europe, and continues to be a major issue for taxpayers and tax authorities. PwC’s network in the CEE region has gathered thorough information on the practices of tax authorities there with respect to transfer pricing. India transfer pricing audits: Challenges and emerging trends Transfer pricing audits in India have typically been characterised by intense scrutiny and aggressive positions by transfer pricing officers. Therefore, it is critical that multinationals with operations in India remain thoroughly up to date about ongoing audit issues, and plan their transfer prices as well as audit/appeal strategy accordingly. This article examines in detail major audit issues for taxpayers and emerging areas of focus of Indian tax authorities. New entrants, increased enforcement: The Latin American perspective Generally, transfer pricing in Latin America follows different scenarios than in most other regions. Brazil, for example, has its own set of (non OECD-compliant) rules applicable to transfer pricing matters. Yet even in countries in the region that do not have specific transfer pricing regulations, significant compliance requirements are in force, and we expect to see increased scrutiny by tax authorities on the full range of transfer pricing issues. New entrants, increased enforcement: The Chinese perspective After years of granting tax holidays and incentives to many multinational companies operating in China, the erosion of China’s tax base has become a top priority for the country’s tax authority, the State Administration of Taxation. In tandem with the global trend, China in January, 2008, passed a new corporate income tax law. This article provides a summary of China’s transfer pricing regulatory landscape under this significant new law. |
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