Transfer pricing is taking over. It's is on the lips of every tax practitioner and it's not going to go away. In the past year the debate over how to tax cross-border related-party transactions has been fired-up by the UN, which is looking to simplify the OECD's transfer pricing guidelines in a practical manual for developing countries.
The OECD has taken a number of hits from non-government organisations who say it excludes poorer countries from its transfer pricing policies and is biased towards the arguments of richer, western countries.
The OECD's latest thinking on transfer pricing came in a discussion draft on the transfer pricing aspects of intangibles that came out in June 2012, more than a year ahead of the original timetable.
This early release came as an even more welcome surprise to professionals who feared delays in the project after the OECD's two most senior transfer pricing officials left last September. They were replaced by Marlies de Ruiter as the head of the tax treaties, transfer pricing and financial transactions division and Joe Andrus as head of the transfer pricing unit.
Transfer pricing and intellectual property is the subject of the article in this guide by Yves Herve and Susann van der Ham of PwC Germany.
And Thomas Borstell and Loren Ponds, of Ernst & Young's global transfer pricing team discuss the increasingly uncertain environment that taxpayers have to negotiate when organising their transfer pricing.
Zoltán Lipták of Ernst & Young in Hungary promotes the benefits of applying for advance pricing agreements in the country.
Ay Tjhing Phan and Ravi Gupta of PwC Indonesia explain how transfer pricing is emerging as the key weapon the authorities are using to fulfil their tax collection objectives.
Philippe Neefs and Sophie Boulanger of KPMG discuss the investment benefits to Luxembourg and the transfer pricing aspects that come with it.
Svetlana Stroykova, Ilarion Lemetyuynen, Adam Kosmala and Andrew Joshi of PwC provide an overview of the changes in the Russian transfer pricing regime and Jens Brodbeck and Carmen Gers of ENS – Taxand outline the changes to South Africa's regime.
Simon Huang of PwC explains the trend for self-initiated transfer pricing adjustments in Taiwan.
In the UK the changes to the controlled foreign company regime have had an impact on transfer pricing and Batanayi Katongera and Matthew Wentworth-May of Olswang describe how.
And finally, David Forst of Fenwick & West summarises the most important changes in the US market.
We hope you find these articles useful when organising your global transfer pricing affairs.
Sophie Ashley
Editor, TPWeek.com
