Tp Analysis
GLOBAL TRANSFER PRICING SERVICES
Global Transfer
Pricing Review kpmg.com TAX
Contents
Introduction
Regional Insights
7
Country Snapshots
26
Country Overviews
32
GTPS Publications
195
Contact List
GTPS_Brochure_Final.indd 1
2
202
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2 | Global Transfer Pricing Review
Introduction
GTPS_Brochure_Final.indd 2
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Introduction | 3
The long term growth in international trade, combined with the challenging global economic environment and growing fiscal deficits has many governments extremely focused on tax base protection. This has heightened government scrutiny of transfer pricing matters, including issues such as attribution of losses, business restructuring, intellectual property migration, financing transactions and others. Given this focus, transfer pricing rules and regulations are rapidly evolving.
Notably, the Organisation for Economic Co-operation and
Development (OECD) Council approved on 22 July 2010 the 2010 version of Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The 2010 version is the first substantial revision of the OECD Guidelines since they were first issued in
1995. Notable changes include:
• Adoption of a “most appropriate method” standard for choice of transfer pricing method, replacing the previous hierarchy that preferred “traditional transactional methods” such as the
Comparable Uncontrollable Price method over “transaction profit methods” such as the Transactional Net Margin Method;
• Substantial additional guidance on comparability, now appearing in Chapter III; and
• Addition of Chapter IX, containing a detailed discussion of the transfer pricing treatment of business restructurings.
KPMG member firms anticipate significant variations in the pace at which the revised Guidelines will affect local transfer pricing rules and tax authority practices. While some countries may
Global Transfer
Pricing Review kpmg.com TAX
Contents
Introduction
Regional Insights
7
Country Snapshots
26
Country Overviews
32
GTPS Publications
195
Contact List
GTPS_Brochure_Final.indd 1
2
202
15/02/11 7:13 PM
2 | Global Transfer Pricing Review
Introduction
GTPS_Brochure_Final.indd 2
15/02/11 7:13 PM
Introduction | 3
The long term growth in international trade, combined with the challenging global economic environment and growing fiscal deficits has many governments extremely focused on tax base protection. This has heightened government scrutiny of transfer pricing matters, including issues such as attribution of losses, business restructuring, intellectual property migration, financing transactions and others. Given this focus, transfer pricing rules and regulations are rapidly evolving.
Notably, the Organisation for Economic Co-operation and
Development (OECD) Council approved on 22 July 2010 the 2010 version of Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The 2010 version is the first substantial revision of the OECD Guidelines since they were first issued in
1995. Notable changes include:
• Adoption of a “most appropriate method” standard for choice of transfer pricing method, replacing the previous hierarchy that preferred “traditional transactional methods” such as the
Comparable Uncontrollable Price method over “transaction profit methods” such as the Transactional Net Margin Method;
• Substantial additional guidance on comparability, now appearing in Chapter III; and
• Addition of Chapter IX, containing a detailed discussion of the transfer pricing treatment of business restructurings.
KPMG member firms anticipate significant variations in the pace at which the revised Guidelines will affect local transfer pricing rules and tax authority practices. While some countries may