This report addresses the practical administration of transfer pricing programmes by tax administrations. Technical analysis of how transfer prices should be computed in accordance with the arm’s length principle is outside the scope of this report. Instead the report focuses on the practical experiences of a number of FTA member countries and some non-member countries. The report discusses ways in which the management of transfer pricing programmes can be optimised, so that transfer pricing audits and enquiries are conducted efficiently and in a timely manner, for the benefit of MNEs and tax administrations alike. It is concerned with the practical steps tax administrations need to take to correctly identify transfer pricing cases that merit audit or enquiry and then to progress those cases to as early a conclusion as possible.
Table of contents:
Chapter 1. Introduction Chapter 2. Selecting the right cases Chapter 3. Getting off to a good start Chapter 4. Governance arrangements Chapter 5. Maintaining progress, tackling delay Chapter 6. Reaching a decision point Chapter 7. Resources, skllls and use of specialists Chapter 8. Transfer pricing and developing countries Annex A. Denmark Annex B. South Africa Annex C. France Annex D. Transfer pricing risk identification and assessment: the perspective of an advisor of MNEs Annex E. Cloud computing
