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Transfer pricing perspectives: Re:solutions moving towards certainty
Transfer pricing results in uncertain tax positions: Multinations are being buffeted by conflicting forces: Unprecedented tax authorities hungry for revenue on the one hand, and restive stakeholders needing some kind of certainty on the other.
Overview
By its very nature, transfer pricing results in uncertain tax positions, requiring multinational companies to face the challenge of meeting the competing demands of tax authorities and of stakeholders. The present economic situation—which has made the former more aggressive and the latter more cautious—has only aggravated this fundamental challenge.

In response, PwC has prepared this publication, which offers valuable insights and strategies on how to meet the increased transfer pricing challenges during recessionary times.

Among the areas covered are:
  • The taxation of permanent establishments;
  • Business restructuring;
  • Implications of IFRS on cost sharing arrangements; and
  • Insights on Indian, Chinese, Latin American and Eastern Europe perspectives.

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Contacts
Global
Garry Stone
Global transfer pricing leader
Tel: +1 (312) 298 2464