Arcotia Hatsidimitris - International Tax Dialogue

More documents

Recommendations

Info

18 – 1. INTRODUCTION Notes 1 Model Tax Convention on Income and on Capital (www.oecd.org/ctp/tt/mtc); United Nations Model Double Taxation Convention between developed and developing countries (http://www.un.org/esa/ffd/documents/DoubleTaxation.pdf) 2 Lanz, R. and S. Miroudot (2011), “Intra-Firm Trade: Patterns, Determinants and Policy Implications”, OECD Trade Policy Working Papers, No. 114, OECD Publishing. http://dx.doi.org/10.1787/5kg9p39lrwnn-en 3 Study into the Role of Tax Intermediaries: www.oecd.org/dataoecd/28/34/39882938.pdf; Building Transparent Tax Compliance by Banks: www.oecd.org/ctp/ta/banks; Framework for a Voluntary Code of Conduct for Revenue Bodies and Banks: www.oecd.org/dataoecd/10/9/45989171.pdf; and Joint Audit Report and Joint Audit Participants Guide: www.oecd.org/dataoecd/10/13/45988932.pdf (Report) and www.oecd.org/dataoecd/10/11/45988962.pdf (Participants Guide). 4 Austria, Canada, Denmark, Finland, France, India, Ireland, Italy, South Africa, the United Kingdom and the United States. 5 For the sake of clarity the term ‘audit’ refers only to fundamental challenges to the arm’s length price. Countries were not asked to provide information about audits whose scope is limited to ensuring that the legal requirements for documentation have been fulfilled. Some countries refer to fundamental challenges to the arm’s length prices used as ‘enquiries.’ For the sake of clarity the term audit or enquiry is used in the rest of this report. 6 In some countries the number of cases settled in any year is small and publication of the full results could compromise taxpayer confidentiality as a result. That is why only summary information has been included in this report. 7 A precise figure is difficult to calculate because countries have slightly different bases for determining when a case commences and when it is concluded, some counting the time from when the return is received and others from the point when a firm decision to enquire into a transfer pricing risk has been taken. DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
2. SELECTING THE RIGHT CASES – 19 Chapter 2 Selecting the right cases This chapter examines the process of risk identification and how tax administrations go about selecting the right cases for transfer pricing audit or enquiry. It examines the information sources on which risks assessments are based and the different ways in which tax administrations approach the information gathering process. It includes a summary of the features that may suggest that a transfer pricing risk is present in a case. It considers the role of commercial understanding in the process of risk identification. DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
Page 1 and 2: ITD Transfer Pricing Conference: Tr
Page 3 and 4: Dealing Effectively with the Challe
Page 5 and 6: 5 a) Organizational set-up Challeng
Page 7 and 8: 5 a) Organizational set-up Head Off
Page 9 and 10: 5 a) Reorganisation in the future H
Page 11 and 12: 5 a) Organizational set-up National
Page 13 and 14: 5 b) Staffing, training and managin
Page 19 and 20: Transfer Pricing Learning Curve Pot
Page 21 and 22: EXAMPLE: Training of the staff - CR
Page 23 and 24: 5 c) Staffing, training and managin
Page 25 and 26: THANK YOU marica.houska@porezna-upr
Page 27 and 28: Dealing Effectively with the Challe
Page 29: FOREWORD - 3 Foreword This report i
Page 33: ABBREVIATIONS - 7 Abbreviations ADR
Page 36 and 37: 10 - EXECUTIVE SUMMARY the fact fin
Page 39 and 40: 1. INTRODUCTION - 13 Chapter 1 Intr
Page 41 and 42: 1. INTRODUCTION - 15 Against this b
Page 43: 1. INTRODUCTION - 17 • The ease o
Page 47 and 48: 2. SELECTING THE RIGHT CASES - 21 I
Page 49 and 50: 2. SELECTING THE RIGHT CASES - 23 I
Page 51 and 52: 2. SELECTING THE RIGHT CASES - 25 T
Page 53 and 54: 2. SELECTING THE RIGHT CASES - 27 d
Page 55: 2. SELECTING THE RIGHT CASES - 29 N
Page 58 and 59: 32 - 3. GETTING OFF TO A GOOD START
Page 64 and 65: 38 - 4. GOVERNANCE ARRANGEMENTS Get
Page 66 and 67: 40 - 4. GOVERNANCE ARRANGEMENTS •
Page 68 and 69: 42 - 5. MAINTAINING PROGRESS, TACKL
Page 76 and 77: 50 - 6. REACHING A DECISION POINT T
Page 78 and 79: 52 - 6. REACHING A DECISION POINT W
Page 80 and 81: 54 - 6. REACHING A DECISION POINT B
Page 82 and 83: 56 - 6. REACHING A DECISION POINT N
Page 84 and 85: 58 - 7. RESOURCES, SKILLS AND USE O
Page 94 and 95:
68 - 8. TRANSFER PRICING AND DEVELO
Page 96 and 97:
Page 98 and 99:
Page 100 and 101:
Page 102 and 103:
Page 105 and 106:
ANNEX A - 79 Annex A: Denmark DEALI
Page 107:
DEALING EFFECTIVELY WITH THE CHALLE
Page 110 and 111:
84 - ANNEX B 4. Please provide a de
Page 112 and 113:
86 - ANNEX B 6. The South African R
Page 114 and 115:
88 - ANNEX B TRANSFER PRICING QUEST
Page 116 and 117:
90 - ANNEX B 6. The following infor
Page 118 and 119:
92 - ANNEX B Financial Interest Ins
Page 120 and 121:
94 - ANNEX B 11. Has the company pr
Page 122 and 123:
96 - ANNEX C In all cases, identify
Page 124 and 125:
98 - ANNEX C The tax audit services
Page 127 and 128:
ANNEX D - 101 Annex D: Transfer pri
Page 129:
ANNEX D - 103 • The approach from
Page 133:
ORGANISATION FOR ECONOMIC CO-OPERAT
show all

Arcotia Hatsidimitris - International Tax Dialogue

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?