PwC has published an informative update addressing hot topics in transfer pricing for different industries.
Key industries and issues addressed comprise the following:
- Oil & Gas: intercompany service charges re: direct/indirect benefit and Competent Authority in non-treaty countries
- Global Audits: MAP, OECD BEPS Action Plan, Cooperative Compliance programs, arms-length principle, PE, GAAR and Strategic Risk Assessment
- Industrial Products: Cost Sharing Agreements, Intangibles, Supply chain management, M&A interaction
- Interco. Financing: Guarantee fees, transfer pricing methodologies
- Financial Industry: Dodd-Frank Act, Regulatory practice coordination with transfer pricing
- Russia TP: New rules 2012 introducing arms-length principle, new Department and work group re: TP, specialized TP group re: intercompany transactions
- S. America: Global marketing/sourcing, intercompany services documentation, currency restrictions
- Real Estate Funding
- ERP Systems and TP
- Politics of taxation: OECD BEPS Action Plan, TP disclosures, PE risks
- Pharmaceutical / Life Sciences
- Value Chain Transformation: Model Maturity matrix
This publication is relevant and timely, including Best Practices and transfer pricing issues for different industries.