Luxembourg

Details

  • Service: Tax, Transfer Pricing Services
  • Type: Business and industry issue, Publication series
  • Date: 4/10/2011

Contact

Philippe Neefs

Partner, Transfer Pricing Leader

Tel. +352 22 51 51 5531

philippe.neefs@kpmg.lu

Managing the Transfer Pricing Implications of Complex Supply Chains 

Transfer pricing around corporate supply chains has become increasingly complex and closely scrutinized in recent years. This new publication from KPMG’s Global Transfer Pricing Services, A World in Transition: Managing the Transfer Pricing Implications of Complex Supply Chains, focuses on 3 discrete types of supply chain issues. April 2011

 

 

Part one discusses the implications of the new Organisation for Economic Co-operation and Development (OECD) Guidelines on Business Restructuring. This section includes specific country perspectives on business restructuring concepts from: Australia, Belgium, Canada, China, Denmark, France, Germany, Italy, Japan, the Netherlands, Spain, the United States and the United Kingdom.

 

The second part focuses on a few selected issues that arise in many multinational enterprise’s (MNEs) supply chains.

 

The last section of this publication discusses controversy, including a discussion of two new tools to help taxpayers resolve controversy -accelerated competent authority procedures (ACAP) and binding arbitration- as well as a discussion on navigating transfer pricing controversy in India. The section looks at the rapid growth of advance pricing agreements (APAs) in Asia and includes APA-statistics in Australia, China, Japan and Korea. Finally, it includes a discussion of two court cases that have significant implications for supply chain management and restructuring, namely the General Electric case in Canada and the Veritas case in the United States.

 

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