Arcotia Hatsidimitris - International Tax Dialogue

More documents

Recommendations

Info

28 – 2. SELECTING THE RIGHT CASES Key thoughts for the chapter The challenge for tax administrations is to maximise yield while ensuring that business and other stakeholders have confidence in the tax system. This requires transparent processes for deciding how tax compliance risks are to be addressed. This is particularly important in the context of transfer pricing audits and enquiries which can be very resource intensive for tax administrations and business alike. Business, their advisers and tax administrations are all agreed that the benefits of effective transfer pricing risk identification include: • More targeted and thus more cost-effective use of limited resources from a tax administration’s perspective; • Clearly defined documentation requests which reduce both the demands on business in providing the documentation and the time and other resource burdens on the tax administration in reviewing it; and • Shorter timescales for audits or enquiries and for resolving disputes, which are clearly advantageous to both business and tax administration. DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
2. SELECTING THE RIGHT CASES – 29 Notes 1 See for example Guidance Note - Compliance Risk Management: Managing and Improving Tax Compliance www.oecd.org/dataoecd/44/19/33818656.pdf and the more recent Evaluating the Effectiveness of Compliance Risk Treatment Strategies - Guidance Note http://www.oecd.org/dataoecd/59/3/46274278.pdf 2 The Compliance Assurance Process (CAP) pilot program for large corporate taxpayers in the United States is an example of a process that allows this to happen, although CAP is not limited to transfer pricing issues. 3 Joint International Tax Shelter Information Centre. Details can be found here: http://www.hmrc.gov.uk/avoidance/aag-jitsic.htm 4 The transfer pricing aspects of intangibles are currently being discussed by Working Party No. 6 of the Committee on Fiscal Affairs on the Taxation of Multinational Enterprises, through a Special Session on the Transfer Pricing Aspects of Intangibles set up for this purpose. 5 http://www.oecd.org/dataoecd/22/54/45690216.pdf 6 For a discussion of the Enhanced Relationship, see Chapter 8 of “Study into the Role of Tax Intermediaries”: www.oecd.org/dataoecd/28/34/39882938.pdf. 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 and 44: 1. INTRODUCTION - 17 • The ease o
Page 45 and 46: 2. SELECTING THE RIGHT CASES - 19 C
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: 2. SELECTING THE RIGHT CASES - 27 d
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 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?