On February 12 2013, the OECD issued its report on Base Erosion and Profit Shifting (BEPS). The report is the OECD’s first substantive step with respect to the review and analysis of base erosion and profit shifting. An important part of the report relates to transfer pricing. Ronald van den Brekel of Ernst & Young provides a summary of the BEPS report, in particular in relation to transfer pricing and the direction the OECD may take.
Base erosion and profit shifting (BEPS) is intended to describe the phenomenon that governments lose substantial corporate tax revenue because of planning aimed at eroding the taxable base and/or shifting profits to locations where they are subject to more favourable tax treatment. Oliver Wehnert, Ernst & Young’s EMEIA transfer pricing leader, explains the impact the project may have on transfer pricing.
The inclusion of the China country practices chapter, as part of the UN Practical Manual on Transfer Pricing for Developing Countries (draft version) indicates a great leap in the transfer pricing (TP) administration of the State Administration of Taxation (SAT). Han Jin Ping, tax manager at Siemens, China, discusses the importance of the chapter and the international message it conveys on contract R&D.
Over the last couple of months, Chilean taxpayers have been subject to new transfer pricing compliance requirements, which have significantly changed their perception of the proper way to handle intercompany transactions. Roberto Carlos Rivas, Carolina Alexandres and Gabriel Bernal of PwC Chile explain how taxpayers can navigate through the changes.
Susann van der Ham and Carsten Hüning of PwC Germany discuss recent developments in tax audits practice towards transfer pricing risk assessments strategies.
Each year Mexican taxpayers typically review their intercompany transactions before the end of the fiscal year and later prepare the transfer pricing documentation after the fiscal year has ended. Marta Milewska and Fred Barrett of PwC explain how it is done.
In 2011, Russia enacted revised transfer pricing (TP) rules. However, over the last 18 months the Russian Tax Authority (RTA) has issued various letters clarifying its views on the new TP rules. Evgenia Veter, Steve Cawdron, Anuar Mukanov and Filip Vukovic of Ernst & Young have interpreted these clarifications and their potential impact for businesses as they attempt to comply with the revised legislation.
Transfer pricing regulations and documentation requirements have been in effect for almost nine years, since the end of 2004, and the Taiwanese tax authorities have accumulated more and more experience and knowledge. Paulson Tseng of PwC gives an overview of the Taiwanese tax authorities’ comments on how taxpayers should prepare transfer pricing reports and discusses recent tax auditing practice.
Historically, transfer pricing rules in Ukraine have been vague and were seldom applied by the Ukrainian tax authorities. Konstantin Karpushin, Anna Korobova and Oleksandra Tovkun of KPMG explain why taxpayers need to adopt a long-term view on their transfer pricing strategy.
There have been a number of important US developments in transfer pricing in the past 12 months. Kenneth Clark, Ronald Schrotenboer and David Forst of Fenwick & West provide a brief review and highlight a number of these developments.