Be Prepared for Transfer Pricing Challenges
In today’s global economic environment, tax authorities around the world are very much focused on protecting their tax base, especially in the post-COVID-19 pandemic world. As compared to the last decade, the attention of tax authorities have diverted to the area of transfer pricing, resulting in a surge of numerous court cases, some involving Fortune 500 companies.
These cases have helped shaped the changes to the development of transfer pricing regulations and guidance globally. The proliferation of transfer pricing documentation requirements and penalties are now more visible than before. Additionally, with the evolvement of the Base Erosion and Profit Shifting (“BEPS”) initiative, complexities surrounding transfer pricing planning and compliance have been amplified. In addition, the lack of transfer pricing guidance leaves taxpayers vulnerable to potential transfer pricing challenges resulting in adjustments to the income subject to tax or deductions on expenses from tax authorities.
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