Crowe Horwath International’s Transfer Pricing practice provides economic consulting services in connection with tax issues arising from transactions among controlled parties. Our transfer pricing services seek to determine whether the pricing of intercompany transactions is consistent with the arm’s length standard.
Through Crowe Horwath International’s network of firms, we have extensive resources worldwide to assist companies with their transfer pricing needs.
Intercompany transactions include:
■ Sale and purchase of tangible goods
■ License of intangible property rights
■ Provision of services
■ Financial transactions, including loans
■ Cost sharing agreements Increased Scrutiny and BEPS Tax authorities are increasingly focused on whether multinational companies use transfer pricing to shift income to low-tax jurisdictions where there is little economic activity.
The number of transfer pricing inquiries and audits has increased in many countries, and many tax authorities and legislatures have in recent years acted unilaterally to address perceived tax avoidance strategies.
Base Erosion and Profit Shifting (“BEPS”): In late 2014, The Organisation for Economic Co-operation and Development (“OECD”) and the Group of 20 Nations (“G-20”) began releasing a series of 15 BEPS action plans with the goal of harmonizing international tax and transfer pricing rules, and ensuring that profits are taxed where economic value is being created. more
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