Dispute resolution crucial to sustaining global transfer pricing strategies - PricewaterhouseCoopers International transfer pricing 2009 book addresses issues of growing concern to multinationals.

With strategic dispute resolution increasingly crucial to companies' efforts to sustain their global transfer pricing strategies, PricewaterhouseCoopers (PwC), in its International transfer pricing 2009 book, anticipates an increase in disputes globally as more and more tax authorities attempt to enforce their transfer pricing rules aggressively.

“In 2009 we expect that several major territories will adopt new or revised requirements for transfer pricing and the impact of the OECD’s discussion draft on business restructurings will be evaluated, ” said Gavan Ryle, Tax Partner, PwC Ireland.

Over the past 12 months, several new countries have implemented either formal or informal transfer pricing documentation requirements. A growing problem facing multinational enterprises is the issue of preparing documentation to demonstrate compliance with transfer pricing rules across multiple jurisdictions. More and more tax authorities have established documentation rules that require companies to state clearly and with supporting evidence why their transfer pricing policies comply with the arm’s length standard. Many jurisdictions have also implemented strict penalty regimes to encourage taxpayers’ compliance with these new procedures. These conflicting pressures need to be reviewed and managed, both to meet the burden of compliance and to avoid costly penalties, notes PwC.

The 2009 edition of this annual book from the PwC global transfer pricing network addresses the significant changes in the area of transfer pricing since the prior year edition, with several new countries implementing transfer pricing documentation requirements over the past several months. In its eleventh iteration, the 2009 edition contains the latest developments and updates on technical material.

Gavan Ryle continued: “Transfer pricing is a matter of fundamental importance to multinational enterprises based in Ireland. Today, a properly coordinated defense strategy is a basic necessity rather than an expensive luxury. We hope that this book will enable multinational enterprises to better navigate their way in this very real climate of change in which they are operating.”

ENDS

To download or order a copy of International transfer pricing 2009, please visit our dedicated website on www.pwc.com/internationaltp.

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About PwC's transfer pricing practice

With the ever-increasing scrutiny of transfer pricing activity by tax authorities worldwide, PricewaterhouseCoopers strives to assist its clients in the development of tax-efficient structures that help them increase compliance with legal requirements, prepare for rapid audit response, resolve transfer pricing disputes and increase transfer pricing exposure in future periods.

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