A newly released
KPMG report warns
tax authorities are seeking to enforce transfer pricing regulations and are
likely to consider a broader range of company transactions which can result in
more detailed investigations.
Among the ‘red flags’ which signal further investigation include unusually
high profits or losses in a group company; corporate restructurings involving
closures or reductions in operations; significant inter-company management fees;
dealings with a group company in a tax haven; and location in a low cost
These are some of the instances of tightening regulations discussed in the
newly released publication, A Meeting of Minds – Resolving Transfer Pricing
Controversies, which focuses on transfer pricing controversy issues and
resolution alternatives which incorporates contributions from 39 KPMG authors
from 19 countries.
‘Companies operating internationally are discovering that their transfer
pricing positions may face challenges from one tax authority, even when that
position is well-supported and accepted by other tax authorities operating under
the umbrella of the OECD Guidelines,’ Andrew Hickman, KPMG UK partner, global
transfer pricing services, said.
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