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PKF International

A global family of legally independent firms

PKF Worldwide Transfer Pricing Guide 2017/18

Publications

PKF Worldwide Transfer Pricing Guide 2017/18

We are proud to present you with our latest flagship publication. The PKF Worldwide Transfer Pricing Guide 2017/18 provides up to date TP information on 98 tax jurisdictions.

Against the backdrop of globalisation and rapidly increasing international trade, multinational enterprises have become more sophisticated in how they plan their business operations across various jurisdictions. Indeed, transfer pricing is often seen as a mechanism for a multinational group to move profits into a low tax jurisdiction and costs into a higher taxed jurisdiction as a means of achieving a lower overall taxation result. Consequently, with countries experiencing reduced tax bases and declining tax revenues the pressure has never been higher on Governments and tax authorities to ensure the transfer prices between domestic and foreign related parties reflect arm’s length values and domestic tax revenues are protected.

To provide guidance to countries in regulating and monitoring the transfer prices between large taxpayers and their overseas related parties, an area of focus of the Organisation for Economic Co-operation and Development (OECD) in its Base Erosion and Profit Shifting (BEPS) initiative was transfer pricing. Notably, following action points 8 to 10 and 13 of BEPS (which addressed transfer pricing issues) we have seen countries introducing increased transfer pricing penalty regimes, higher compliance obligations for taxpayers, and increased documentation requirements (often following the recommended three-tier country-by-country (CbC) reporting, master file and local file approach of BEPS).

PKF has a global transfer pricing practice and provides a one-stop service for multinational groups in taking care of their transfer pricing requirements across many jurisdictions. With offices in over 400 locations, we operate in more than 150 countries across our 5 regions, and specialise in providing high quality transfer pricing services to international and domestic organisations in all our markets. We can assist you in managing your transfer pricing policies and documentation are BEPS-proof.

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