The double taxation risks in cross-border restructuring
19 September 2011
Ralph Cunningham in Paris
The OECD project on the transfer pricing aspects of business restructuring has clarified a lot of the issues around the topic since it began in 2005, but uncertainties still remain, the annual congress of the International Fiscal Association (IFA) was told on Monday.
The project ended in the adoption of a new chapter 9 in the OECD's transfer pricing guidelines in July 2010.
“Tremendous progress was made between the controversial roundtable with business in 2005 about restructuring and 2010 guidance,” said Michelle Levac, of the Canada Revenue Agency, who chairs the OECD's Working Group No 6 on transfer pricing.
Subject 1 of this year's IFA congress covered cross-border restructuring and panellists, which included Caroline Silberztein, the outgoing head of transfer pricing at the OECD, Levac and Tim McDonald, vice-president of international tax for Procter & Gamble, provided tips for taxpayers, tax authorities and the OECD about how to achieve their own objectives when dealing with business restructurings.
Edward Morris of Deloitte in the UK emphasised transfer pricing documentation. He said intra-group contracts do not...
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