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Transfer pricing enters new age

International Tax Review’s 10th annual Global Transfer Pricing Forum will be an opportunity for transfer pricing professionals from business, government and private practice to focus on the key issues in related-party transactions.

They will get a chance to discuss the strength of the arm’s-length standard and prepare themselves and their organisations for the challenges to come in areas such as transfer pricing dispute resolution, tax efficient supply chain management and the role transfer pricing plays in financial transactions.

The economic challenge for governments has changed in recent months. From being one of how to create growth so their economies came out of recession, it has become a battle to reduce public debt. Budget deficits of hundreds of billions of dollars mean that every source of income is being tapped like never before. Transfer pricing is one of those.

And if officials are prioritising transfer pricing for revenue, it means that tax and transfer pricing executives need to be aware of the different approaches tax authorities around the world are taking in this area.

Not only are jurisdictions with existing transfer pricing rules looking to enforce them more strictly, other countries have put regulations in place for the first time. The challenge for them is to ensure they have the right expertise to operate, or if they do not, to know where to get those skills.

The unprecedented financial crisis over the last two years has raised serious questions for taxpayers. For example, is it credible to use lossmaking comparables when setting prices now? Will this practice be acceptable to tax authorities? How do you deal with the increase in jurisdictions that now require documentation? What is the most efficient way to coordinate the production of multiple transfer pricing reports? Are advance pricing agreements worthwhile if economies can change so quickly? Is there scope to renegotiate them? What new dispute resolution mechanisms, other than litigation, are available?

At International Tax Review’s 10th annual Global Transfer Pricing Forum in Amsterdam on September 15 and 16, leading tax directors, officials and advisers will analyse the key issues for transfer pricing managers today and give their insights on the best transfer pricing strategies.

The foremost transfer pricing specialists will tackle issues such as:

  • The future of the arm’s-length standard;

  • Technology-based IP and transfer pricing;

  • Tax-efficient supply chain management; and

  • Dispute resolution

This is in addition to the, by now regular sessions on financial transactions, marketing intangibles and emerging markets developments.

This is your opportunity to hear their views, increase your understanding and prepare for the future of transfer pricing. Over the last 10 years, the Global Transfer Pricing Forum has proved to be the most vibrant and insightful event for the discussion of the critical issues in the field.

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