Centre for Tax Policy and Administration


Dealing Effectively with the Challenges of Transfer Pricing

This report addresses the practical administration of transfer pricing programmes by tax administrations. Technical analysis of how transfer prices should be computed in accordance with the arm’s length principle is outside the scope of this report. Instead the report focuses on the practical experiences of a number of FTA member countries and some non-member countries. The report discusses ways in which the management of transfer pricing programmes can be optimised, so that transfer pricing audits and enquiries are conducted efficiently and in a timely manner, for the benefit of MNEs and tax administrations alike. It is concerned with the practical steps tax administrations need to take to correctly identify transfer pricing cases that merit audit or enquiry and then to progress those cases to as early a conclusion as possible. 

Published on January 18, 2012


Executive Summary
Selecting the right cases
Getting off to a good start
Governance arrangements
Maintaining progress, tackling delay
Reaching a decision point
Resources, skills and use of specialists
Transfer pricing and developing countries
Annex A: Denmark
Annex B: South Africa
Annex C: France
Annex D: Transfer pricing risk identification and assessment
Annex E: Cloud computing
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