Planning for the Recovery found that many transfer pricing systems globally are facing unprecedented stress as the recession forces companies and revenue authorities to reassess their economic expectations. This 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 environment.
Articles in the report deal with a host of difficult issues for tax departments, including: the implications of the downturn and recovery for common intercompany structures, the defense of transfer pricing arrangements in the recession, and the ability of taxpayers to mitigate issues with existing advance pricing arrangements. The collective message is that a longer-term and global perspective is vital to achieving satisfactory results now and exploiting change beyond the current climate for enduring benefit.