International transfer pricing-compliance and documentation, Managerial Accounting

Assignment Help:

International transfer pricing

Transfer pricing is a perennial issue, within the international tax community (Richard Casna, Accounting and Business, in the year February 1988).

As multinationals become more sophisticated in employing transfer pricing techniques in their tax planning, the revenue authorities have increased their scrutiny of arrangements, putting transfer pricing at the forefront of international tax concerns.

It naturally follows that if profits can be shifted from a high tax jurisdiction to one of low tax through transfer pricing, the tax authorities will respond with rules designed to curtail tax avoidance and ensure tax payer compliance.

Revenue authorities around the globe have become more adept at countering the “profit-shifting” aspects of transfer pricing practices and are strengthening their statutory powers with ever more extensive and complex legislation and regulations.

To strengthen the tax authorities’ position, regulations typically introduce specific rules to determine arms’ length prices and require that tax payers maintain very extensive records documenting the methods used to determine their transfer prices (which often necessitates the employment of teams of both in-house and outside counsel, accountants and economists). Provision is made as well for the imposition of very stringent penalties in cases of non-compliance.

To achieve these ends, the statutes generally focus on guidelines set out by the OECD’s Committee on Fiscal Affairs (the tax policy body of the OECD), first in its 1979 document “Transfer pricing and multinational Enterprises” and the 1995-1996 “Transfer pricing Guidelines for Multinational Enterprises and Tax Administrations.” These guidelines usually stipulate the parameters of the arm’s length pricing standard and the methodology to be followed in achieving arm’s length prices.

The practitioner as adviser to multinationals which faces the complexities of transfer pricing legislative and regulatory controls has therefore to simply consider the statutes in each country/state carefully, comply with the rules and maintain extensive documentation.


Related Discussions:- International transfer pricing-compliance and documentation

What are the limitation of performance budgeting, What are the Limitation o...

What are the Limitation of performance budgeting 1) It dose not facilitate qualitative evaluation. 2) The success depends on the well organized departments, but this may not b

Example of credit standards, The current sales of M/s ABC are Rs.100 lakhs....

The current sales of M/s ABC are Rs.100 lakhs. Through relaxing the credit standards the firm can produce additional sales of Rs.15 lakhs on that bad debt losses would be 10 percen

Permanent abandonment of premises, PERMANENT ABANDONMENT OF PREMISES A ...

PERMANENT ABANDONMENT OF PREMISES A company may find it more profitable to concentrate its output in some factories by closing down others.  The decision, in this instance, is

Budget and Budgetary Control, I am to write thesis on Budget and Budgetary ...

I am to write thesis on Budget and Budgetary Contro. Can you please help me with contents and notes?

What is period cost, What is period cost Period costs are those costs w...

What is period cost Period costs are those costs which are reported as expanses of the period in question. These are cost which are not assigned to the product but are charged

Receivables management, In the earlier unit, we have studied how firms dete...

In the earlier unit, we have studied how firms determine their requirements for current assets and manage their holdings in cash and marketable securities. Inside a classical manuf

Explain the process of financial intermediation, Question 1: i) Explai...

Question 1: i) Explain the process of financial intermediation and discuss the existence of banks. ii) Examine the implications of the existence of financial intermediarie

What are the features of performance budgeting, What are the features of pe...

What are the features of performance budgeting The main features of performance budgeting are:  a)  Classification into functions activities or programmers.  b)  Specifyi

Cash to debt service ratio, Cash to debt service ratio  Cash to debt s...

Cash to debt service ratio  Cash to debt service ratio also known as debt cash flow coverage ratio is an improvement over the interest coverage ratio and is calculated. The

Write Your Message!

Captcha
Free Assignment Quote

Assured A++ Grade

Get guaranteed satisfaction & time on delivery in every assignment order you paid with us! We ensure premium quality solution document along with free turntin report!

All rights reserved! Copyrights ©2019-2020 ExpertsMind IT Educational Pvt Ltd