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

Illustrate the general design of waste heat boilers, Illustrate the General...

Illustrate the General Design of Waste heat boilers The boiler system shall be made up of a fire tube type heat exchanger, a steam drum with relief valve internals, risers and

Choosing order quantity , CHOOSING ORDER QUANTITY (SIZE—PROBLEM) The ob...

CHOOSING ORDER QUANTITY (SIZE—PROBLEM) The objective of inventory decisions is usually to minimize total inventory costs to the company. Costs are ascribed to all elements whic

State the factors of cvp, State the factors of CVP The three factors of...

State the factors of CVP The three factors of CVP analysis I e cost volume and profit are interconnected and dependent on one another . for example profit depends upon sales se

Exercises and Problems, Exercises 2-1, 2-2, 2-3, 2-4 Problem 2-14 I didn’t...

Exercises 2-1, 2-2, 2-3, 2-4 Problem 2-14 I didn’t write every question down out of the book just questions 2-1, and 2-2. Exercise 2-1 classifying manufacturing cost. Your boat,

Introduction to Management Accounting, What is Costco''s Financial decision...

What is Costco''s Financial decisions, Centralized or decentralized?

Problrm question, The std cost of chemical mixture~PQ is as follows: 40% of...

The std cost of chemical mixture~PQ is as follows: 40% of material P @rs.400/kg 60% of material Q @rs.600/kg A std loss of 10% is normally anticipated in pdn. The followinng parti

How much was Topaz’s operating income (income before taxes), How much was T...

How much was Topaz’s operating income (income before taxes) last year?

Bussiness.., #queThe following information pertains to Fairways Driving Ran...

#queThe following information pertains to Fairways Driving Range, Inc.: The company is considering operating a new driving range facility in Sanford, FL. In order to do so, they

What are the disadvantages of activity based costing, Disadvantages of acti...

Disadvantages of activity based costing 1) It is essentially not the panacea for all ills. 2) It absorbs a lot of resources. 3) Too much emphasis on customer viability c

Queue discipline, Queue discipline 1) It refers to the manner in which ...

Queue discipline 1) It refers to the manner in which customers behave in a queue, and to the order in which they are served up. For illustration; A customer may arrive at a que

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