Critical Concerns in Transfer Pricing and Practice

By Wagdy M. Abdallah | Go to book overview

9

Arm's-Length Price and Advance Pricing Agreement Programs in Selected Countries

Transfer pricing is considered one of the most important as well as complicated business issues in the world. This complexity is compounded when transfer pricing is combined with e-commerce crossborder business transactions. As globalization and Internet technology continue so quickly, all tax authorities worldwide are paying close attention to transfer pricing issues and trying to change their tax regulations and rules at a fast pace, which can mean headaches for corporate and financial executive officers of MNCs. However, the upside is that many countries are adopting a similar approach to eliminate or reduce tax abuses or evasion as a result of using non-arm's-length transfer pricing techniques.

This chapter and chapter 10 are concerned with recent international developments and changes in tax regulations and practices of transfer pricing legislation with respect to four different transfer pricing issues: transfer pricing in general, including arm's-length standards; advance pricing agreement programs; documentation; and penalties. This chapter covers the first two issues of transfer pricing systems: arm's-length price standard and the advance pricing agreement programs in selected countries. Chapter 10 covers documentation and penalties of transfer pricing in the same selected countries. Comparative analysis of selected countries in different areas of the world is presented. The two chapters also concentrate on the countries that are important to the executive officers of American multinational companies. The selected countries, in alphabetical order, are Canada, France, Germany,

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