TP Update: Failing to Plan, is Planning to Fail and Can Cost a Company Dearly
Many businesses feel that transfer pricing is merely a regulatory requirement. Businesses fail to accurately identify the benefits of conducting a thorough and well planned transfer pricing analysis. Undertaking a thorough and contemporaneous analysis of a company's transfer pricing and ensuring that the policies and actions put in place are in the global interests of the company, a company can greatly reduce its global tax bill and ensure that its activities are being run in the most efficient and effective manner. Without adequate planning a company may end up incurring double taxation expenses, or a larger global tax bill, than if they had planned sufficiently and effectively implemented their transfer pricing policy.
A proper and effective analysis of a company's transfer pricing policy can provide a great deal of benefit for a company. Transfer pricing is seen as a non-exact science, an art even, and the correct approach to transfer pricing implementation can end up assisting a company with their profitability and overall international strategy. There is a significant issue with companies who see transfer pricing as merely a requirement for company's who are looking to 'test the boundaries' of tax laws. It is not merely a malicious intent that tax authorities will investigate. If the transactions and services provided by related parties are not conducted within market terms, the intention of the company is completely irrelevant.
Transfer pricing has arguably become the most important international tax issue currently facing multinational enterprises. It is because of this focus that tax authorities around the world are implementing and updating their rules and regulations on documenting the pricing and terms of intercompany international transactions, as well as increasing their audit activity of the topic. For instance, the IRS is undertaking a large restructuring on the 1st of October 2010. The new Large Business and International division will add roughly 875 employees to the existing international force of 600. This will include a transfer pricing director and a chief economist, who will oversee economic positions pertaining to transfer pricing. This focused restructuring, together with organization of the new Transfer Pricing Practice and its pilot enforcement program, unequivocally signals an intensified emphasis by the IRS on transfer pricing examination and enforcement. Taxpayers are clearly on notice to get their transfer pricing policies in order. This should include a review of transfer pricing studies for all significant related-party cross-border transactions to be sure they are in place, thoughtful, up-to-date and being implemented appropriately.
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It is very important for the people responsible for tax planning and transfer pricing in a company to keep abreast of developments in the global transfer pricing environment. For instance, a recent ruling on a 20-year-old dispute between Ottawa, Canada and GlaxoSmithKline Inc. creates an important precedent in fights with the Canada Revenue Agency, as well as revenue agencies throughout the world. For the years 1990 to 1993, Canadian tax officials accused GlaxoSmithKline PLC’s Canadian arm of overpaying a Swiss-based affiliate for the key ingredient in the stomach-ulcer drug Zantac. In 2008, a judge in Canada’s Tax Court agreed, adding $51-million to the revenue figures. In August however, the Federal Court of Appeal overturned that ruling, saying the judge failed to take into account the “economic reality” when calculating a fair price had the deal been between unrelated parties. The decision sends the case back to the Tax Court for reconsideration.
Transfer-pricing disputes will remain on the front burner for companies' and tax authorities', partly because the math is getting more and more complicated. So much of the value of products in the modern economy is based on “intangibles,” such as a brand-name or intellectual property and these are very difficult for companies and tax collectors to appraise. In addition, the Glaxo case illustrates the importance of considering all the facts and circumstances in determining the arm's length nature of the transaction.
Should you have any questions or concerns about your company's transfer pricing, please do not hesitate to contact our transfer pricing team.
We would be happy to assist you with any requirements you may have. If you have any questions or require additional information, please contact
3 Golda Meir st, Lev Hanitzan, Wiezmann Science Park, Ness Ziona 74036
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TP Update: 
It is very important for the people responsible for tax planning and transfer pricing in a company to keep abreast of developments in the global transfer pricing environment. For instance, a recent ruling on a 20-year-old dispute between Ottawa, Canada and GlaxoSmithKline Inc. creates an important precedent in fights with the Canada Revenue Agency, as well as revenue agencies throughout the world. For the years 1990 to 1993, Canadian tax officials accused GlaxoSmithKline PLC’s Canadian arm of overpaying a Swiss-based affiliate for the key ingredient in the stomach-ulcer drug Zantac. In 2008, a judge in Canada’s Tax Court agreed, adding $51-million to the revenue figures. In August however, the Federal Court of Appeal overturned that ruling, saying the judge failed to take into account the “economic reality” when calculating a fair price had the deal been between unrelated parties. The decision sends the case back to the Tax Court for reconsideration.
Transfer-pricing disputes will remain on the front burner for companies' and tax authorities', partly because the math is getting more and more complicated. So much of the value of products in the modern economy is based on “intangibles,” such as a brand-name or intellectual property and these are very difficult for companies and tax collectors to appraise. In addition, the Glaxo case illustrates the importance of considering all the facts and circumstances in determining the arm's length nature of the transaction.
Should you have any questions or concerns about your company's transfer pricing, please do not hesitate to contact our transfer pricing team.
We would be happy to assist you with any requirements you may have. If you have any questions or require additional information, please contact
3 Golda Meir st, Lev Hanitzan, Wiezmann Science Park, Ness Ziona 74036