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

Mortgages, You want to purchase a house that costs $325,000. You have a dow...

You want to purchase a house that costs $325,000. You have a down payment of $65,000 and will take out a mortgage to make up the difference. The AMC Mortgage Corporation offers a q

Explain operating budgets, Explain Operating budgets These budgets rela...

Explain Operating budgets These budgets relate to the dissimilar activities or operation of a firm the number of such budgets depends upon the size and nature of business. The

Credit period, It refers to the length of time given to the buyer to pay fo...

It refers to the length of time given to the buyer to pay for their purchases. Throughout this period no interest is charged on the excellent amount. The credit period usually vari

What are the advantages of activity based costing, Advantages of activity b...

Advantages of activity based costing 1) It helps understanding the behavior of overhead costs and their relations ship to products services customers and market segments. 2)

Explain the techniques of performance budgeting, Explain the techniques of ...

Explain the techniques of performance budgeting It will also be useful to examine the three major aspects of this technique: Structural aspects : the structural aspects inv

Determine the application of zero base budgeting, Application of zero base ...

Application of zero base budgeting In the following areas ZBB may be applied: 1) redundant schemes may be discontinued 2) identify the duplicate schemes and merge them in

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