Current and Former U.S. Officials, Local Country Private Practitioners to Tackle Issues of Operating in BRIC Countries


 Multinational companies operating in the BRIC countries face some daunting challenges. In Brazil, government-imposed profit margins cause frequent double taxation. In Russia, OECD-style transfer pricing rules were adopted only last July. India has some of the world’s most aggressive auditors, and the government’s new budget contains a provision that could retroactively reverse the result in the Supreme Court's taxpayer-favorable Vodafone ruling. In China, the government just announced that it recovered an additional $3.8 billion in tax for 2011 from its transfer pricing activities, and practitioners predict the nation's fast-growing consumer products industry will continue to be a target for audit.

Along with local country private practitioners, Michael Danilack, IRS Deputy Commissioner (International), and Carol Dunahoo of Baker & McKenzie, a former U.S. Competent Authority, will examine recent transfer pricing developments and current practice in the emerging and growing BRIC economies. The session will cover tax examinations and alternative dispute resolution forums, controversies and practical experiences, and emerging issues specific to each jurisdiction.

Molly Moses
Managing Editor, Transfer Pricing Report