Transfer Pricing Special Report Selected Issues in Transfer Pricing This Transfer Pricing Special Report carries the best articles from the Transfer Pricing Report during 2007 and covers a variety of important and contentious topics between governments, including:
Building a Transfer Pricing Defense: A Practical Guide Documentation requirements have surged in recent years to a level surprising even those with the most vivid imaginations. While contemporaneous documentation requirements were initially the “playing field” of countries such as the United States, other countries are now using transfer pricing as ideal revenue-generating subject matter: an easy audit target that can produce substantial adjustments. This Special Report delves into what you can do to properly build a transfer pricing defense and covers documentation requirements, diversification v. harmonization, a best practice, the impact of non-compliance, the lost opportunity of planning, and more. Get your free copy here! Transfer Pricing Rules and Practices in India This Special Report covers India’s principal government and fiscal authorities’ attitudes toward cross-border commerce, a history of India’s transfer pricing legislation, onus of proof, preferences for methods, comparable data, contemporaneous documentation, and more. Get your free copy here! International trade and foreign direct investment patterns are increasingly shifting from manufacturing to services. This Special Report addresses the implications for businesses as both home and host governments apply the arm's-length standard to offshored services functions. Since transfer pricing services regulations are much less developed than those for goods and raw materials, multinational enterprises are expected to follow the benefit-cost principle, with little explicit guidance as to acceptable methodologies compared to the detailed guidelines available for tangibles. Get your free copy here! Identifying, Valuing, and Migrating Intangibles: Trouble Ahead Intangibles are a key focus of governments as they audit companies’ transfer prices. Leading practitioners examine the difficulties of determining when intangibles exist and of putting a value on them when they do. They also address the spill-over effect in the fields of customs valuation and indirect taxes. Intangibles laws and policy prevailing in individual European nations and in the United States are discussed in depth. Get your free copy here! |
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