Arcotia Hatsidimitris - International Tax Dialogue

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66 – 7. RESOURCES, SKILLS AND USE OF SPECIALISTS Box 18. Canada Canada’s experience is different: Canada is one of a number of countries that did not make routine use of economists but is now increasing the number of economists it employs. The CRA currently has 20 economists in the International Tax Division and about 12 economists work for the Competent Authority. The 20 economists are embedded in the International Audit Team and work alongside auditors. As a result they travel around Canada a good deal. CRA has a university recruitment program for those with a Master’s degree or PhD and they receive further training and have a specific career track. Auditors in the field value the services provided by economists in transfer pricing cases. CRA has found it is useful to involve economists in the initial risk assessment process and in the appeals function. Overall it is clear that transfer pricing is a specialised subject and, while organisational models vary between tax administrations for good reasons, they all need to address the need to build up the necessary expertise and experience of managing transfer pricing issues. Knowledge management, which seems to go hand in hand with good governance, plays an important part in improving the quality and consistency of transfer pricing settlements. The organisation of the work should also help to develop a good working relationship between specialists and general auditors working on the case. Tax administrations have also found external specialists to be of value but they need to look for opportunities to secure knowledge transfer from those specialists where they can and have to manage the costs involved with some care. Key thoughts for the chapter Many tax administrations face a constant challenge in maintaining sufficient expertise in their organisation to tackle the toughest transfer pricing cases. Improving knowledge management and training are essential to meeting this challenge. For some tax administrations that is best done through the use of large, mixed teams whose members develop complementary skills and experience. Others maintain a core team of specialists who support colleagues in front line units. External specialists also have an important part to play in supporting the transfer pricing work of tax administrations. DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
8. TRANSFER PRICING AND DEVELOPING COUNTRIES – 67 Chapter 8 Transfer pricing and developing countries This chapter is concerned with the challenges developing countries face in the field of transfer pricing. It considers some of the ways in which those challenges can be overcome and the part international co-operation has to play. It also looks at ways in which access to information and comparables could be improved in developing countries. DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
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THANK YOU marica.houska@porezna-upr
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FOREWORD - 3 Foreword This report i
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Arcotia Hatsidimitris - International Tax Dialogue

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