Arcotia Hatsidimitris - International Tax Dialogue

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76 – 8. TRANSFER PRICING AND DEVELOPING COUNTRIES achieve this. This will represent a valuable addition to the work of the Global Forum on Transparency and Exchange of Information for Tax Purposes and the Informal Task Force on Tax and Development. In general, developed countries have larger networks of information exchange and double taxation agreements than developing countries. They are therefore likely to have more experience of negotiating exchange of information articles in their treaties and tax information exchange agreements. These are skills which could be shared to good effect with developing countries and should be included in the register referred to above. Key thoughts for the chapter Over the last five years developing countries have grown their awareness of the risk of significant tax loss through transfer pricing and the importance of developing their skills and expertise to meet this challenge. Although many multi-national enterprises invest significantly to ensure that transactions which do not take place in an open market are priced properly, a number do not and there are growing concerns that the economies of developing countries are disadvantaged by their failure to do so. Many of the issues faced today by developing countries share common features and have previously been addressed by others. It follows that the best source of support for developing countries in the context of transfer pricing lies in closer international collaboration amongst developing countries in comparable situations and more widely in the international community. This will help tax administrations in developing countries to improve their transfer pricing skills and knowledge while at the same time levelling the trading playing field across the globe. There are two key recommendations to assist this process. First, delivering the register referred to above. With co-operation from all members of the FTA it should not be too difficult to develop. The FTA could also help to develop a diagnostic tool that will help developing countries to identify the aspects of their transfer pricing regime that are priorities for improvement. That will allow them to make more informed choices between the types of assistance catalogued on the register. Second, ATAF is already planning a conference on transfer pricing to share knowledge and build expertise. This should take place in an ATAF member country during 2012. The FTA should work with ATAF to agree how it can contribute to that event and help partner experienced and less experienced tax administrations to find solutions to key challenges on transfer pricing that are the right solutions in the context of the individual needs of African countries. The OECD Task Force is already closely involved with this event. The FTA and the Task Force will co-ordinate their contributions. The FTA should lend its support to the joint European Commission, OECD and World Bank pilot study in Ghana and, if this is a success, it could be extended to other countries. More generally, the FTA should encourage all countries to adopt a more pragmatic approach to transfer pricing, recognising that it is more of an art than a science. In this context the work of the United Nations on a practical manual on the application of the arm’s length principle is very welcome, as is the work that the OECD’s Working Party 6 is now commencing on the simplification of transfer pricing. DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
8. TRANSFER PRICING AND DEVELOPING COUNTRIES – 77 Notes 1 The full title of the report is "A Report from the International Organisations mandated by the G20 to support the development of more effective tax systems" and was prepared by the IMF, the OECD, the United Nations and the World Bank. 2 The term “cloud” has been around for a while but the cloud symbol is now commonly used to represent the Internet. “Cloud computing” is a generic term for the delivery of information technology services over the Internet. Probably the most basic form of cloud computing service is the provision of data storage but cloud computing services now extend well beyond the provision of data storage facilities over the Internet. A fuller explanation of cloud computing is set out in Annex 6. 3 Ibid. DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
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