Transfer pricing perspectives: Winds of Change - PwC

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Advance Pricing Agreementsin the Asia Pacific56
The Asia Pacific (APAC) region is increasingly regarded bymultinational corporations (MNCs) as the key driver for globalgrowth and expansion. This has led to a surge in cross bordertransactions within APAC region and between the APAC regionand the rest of the world. Furthermore, as corporate structuresare less driven by geographies and more by other businessdrivers like product/business units, corporate structuresare ever more crossing geographical regions and countryboundaries. However, tax authorities are still, and will alwaysbe, dictated by national boundaries. As such, in recent yearstransfer pricing has become a central issue for MNCs and therelevant tax authorities. While the arm’s length principle isfollowed by most tax authorities in the APAC region to evaluateinter-company transactions, different interpretations andemphasis may lead to different outcomes. Hence, tax authoritiessee transfer pricing as a soft target with the potential to producea sizeable increase in tax revenue. This potentially results ineconomic double taxation and an increase in the effective taxrate of MNCs.Transfer Pricing Perspectives. October 201157
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2 Transfer Pricing Perspectives. Oc
Page 6: Russia adopts new transfer pricing
Page 9: Starting in 2014, domestic related-
Page 15 and 16: The trend of centralisation in mult
Page 17 and 18: The new frontier - centre-led model
Page 19 and 20: Limited risk entities and true‐up
Page 21 and 22: Is it possible to mount an argument
Page 23 and 24: Value Chain Transformation -beyond
Page 25 and 26: Governments around the globe are fo
Page 27 and 28: ProcessesTransfer pricing managemen
Page 29 and 30: TPi - Data ManagementMost multinati
Page 31 and 32: ConclusionTPi changes the historic
Page 33 and 34: The question of who takes risky dec
Page 35 and 36: Why cost plus might be the wrongpol
Page 37 and 38: It is not easy to deal with risk in
Page 39 and 40: ConclusionIt will not always be the
Page 41 and 42: Perspectives on risk from GermanyIn
Page 43 and 44: Perspectives on risk from IndiaThe
Page 45 and 46: In 2008, we published an article en
Page 47 and 48: The taxpayer will also want to unde
Page 49 and 50: Proactive preparationTransfer prici
Page 51 and 52: Dealing with risk assessmentsMuch o
Page 53 and 54: Once a taxpayer has identified its
Page 55: ConclusionAlthough it goes without
Page 59 and 60: As can be observed from the diagram
Page 61 and 62: As more transactions involve Singap
Page 63 and 64: AuthorsSpencer ChongPartner, PwC Ch
Page 65 and 66: Conceptualising the challengeIntra
Page 67 and 68: During the course of recent transfe
Page 69 and 70: Passive associationIn performing a
Page 71 and 72: ConclusionsTransfer pricing for fin
Page 73 and 74: Let’s talk business realities!Whi
Page 75 and 76: The appropriateness of using a trad
Page 77 and 78: Following the completion of the rev
Page 79 and 80: Finally, another concern raised rel
Page 81 and 82: Transfer Pricing developments in th
Page 83 and 84: Transfer Pricing Perspectives. Octo
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Transfer pricing perspectives: Winds of Change - PwC

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