The report highlights the need for multinational companies to take a careful look at the guidance from tax authorities, as well as their own current practices, in order to redraw transfer pricing policies in the new and different economic conditions.
The articles deal with a variety of transfer pricing issues, including:
- the implications of the downturn and recovery for common inter-company structures
- the defense of transfer pricing arrangements in the global recession
- the ability of taxpayers to mitigate issues with existing advance pricing arrangements.
The collective message is that many transfer pricing systems globally are facing unprecedented stress as the recession forces companies and revenue authorities to reassess their economic expectations. A longer-term and global perspective is vital to achieving satisfactory results today and exploiting change beyond the current climate for lasting benefit.