European Commission Recommendation of 6/12/2012 regarding measures intended to encourage third countries to apply minimum standards of good governance in tax matters.
The European Commission focuses on automatic exchange of information to be widely applied, per attached reference. Section B.1, Access to Information, provides: Competent authorities of the third country concerned have the power to obtain and provide information that is the subject of a request under an agreement on exchange of information, from any person within their territorial jurisdiction who is in possession or control of such information.
Best Practice points to consider:
- Globally consistent process of providing tax information to all tax authorities
- Coordination of local Business/Regional & Corp. HQ for all transfer pricing responses to tax authorities
- Educating Business Units re: Ways of Working by tax authorities for a better understanding of global risks
- Ensuring local Business Units are aware of general transfer pricing methodologies utilized
- Continual awareness of Business Finance Leaders of transfer pricing risks and exchange of information