Transfer Pricing Perspectives

The revised OECD Transfer Pricing Guidelines (2017) include a detailed risk analysis framework to guide taxpayers and tax authorities on the allocation and assumption of risk under the arm's length principle. The purpose of this article is to review the current stance of tax authorities globally as to how they are intending to use this risk analysis framework in practice.

This article looks at some of the transfer pricing views China and India have been asserting, the influence they have had on the BEPS programme and what might be expected in the future.

Before BEPS asking a TP practitioner what does DEMPE mean? might have elicited a strange response, but BEPS has changed all that. This article discusses DEMPE functions, what are they, which are important and what do they mean for a transfer pricing analysis.

This article discusses what the future holds for Advance Pricing Agreements (APAs) and, potentially, other traditional dispute avoidance tools such as the Mutual Agreement Procedure (MAP).

The rules governing customs duties and transfer pricing often don't align. Managing these inherent disconnections is complex, time consuming and challenging for businesses. This article discusses how to effectively manage these tensions and gain additional cross tax efficiencies and reduce risk/administrative burden.