Considering transfer pricing litigation in a foreign country? Think carefully before acting, as the landscape has changed significantly since the global crisis, and a sophisticated, country-specific strategy is now vital—even as tax authorities are more closely coordinating their enforcement efforts around the world.
As Perspectives: Winds of Change shows, there are many new and potentially onerous legislative and policy procedures to consider before deciding to bring a transfer pricing case in a foreign court—and litigation, rather than negotiation, may sometimes actually be counterproductive to a multinational’s long-term interests.
Perspectives: Winds of Change, a collection of articles evolving from the PwC Global Transfer Pricing Conference 2010, reviews these and other significant policy and legislative developments, including new OECD guidelines and increased documentation requirements in several jurisdictions. Our review covers 14 countries, with representation from all trading continents, and the key industries of automotive, industrial products and energy.