This past year had been tough for the world economy. And while there are signs of a recovery, troubles may still lie ahead. Several major territories, for instance, are now adopting new, or revised, transfer pricing requirements, and there is a discernible increase in disputes globally.
Documenting — and sustaining — transfer pricing in this economic setting can also create difficult issues for tax departments. The continuously uncertain tax positions generated by the transfer pricing process means that multinational companies must now satisfy the ever-increasing demands of tax authorities and stakeholders. The present economic situation has only intensified this situation.