November 27, 2013
We provide to your attention Global TP Survey and Country Guide 2013, which was prepared by the experts of the WTS Alliance under participation of lawyers of KM Partners. The publication provides information regarding peculiarities of transfer pricing in 79 countries worldwide.
The allocation management fees within multinational enterprises was one of the main issues of the survey. According to the OECD Action Plan on Base Erosion and Profit Shifting, the allocation of management service fees is considered to be one of the forms of base erosion and often is a ‘sticking point’ during tax audits. Authors emphasize that despite the fact that many of the analyzed countries have already adopted the control system for transfer pricing, at the moment there is no unified approach to allocation of management service fees: “Where one country could consider the management service charge as base erosion, another country may qualify the same charge as base-protecting”, explains Jan Boekel, WTS Netherlands and author of the survey. That is why the elaboration of adequate transfer pricing documentation taking into account allocation of management fees is the best way to avoid any double taxation or litigation.
We hope that results of the WTS Global TP Survey and Country Guide 2013 research might be useful for you.
More information on WTS Global TP Survey and Country Guide 2013 may be found here:
PPress Release of the survey
*The survey and accompanying materials were provided by our colleagues from WTS World Tax Service B.V.