Global Transfer Pricing
GRANT THORNTON
Global transfer pricing guide
More and more fiscal authorities continue to develop their transfer pricing laws. The principles are common, although interpretations differ from one tax authority to another. Compliance takes time and patience, and the demands and penalties from authorities are increasing. There is greater emphasis on examination and audit activity to encourage compliance and ignoring this issue is not an option for any well-run business. This international transfer pricing guide provides an overview of the different transfer pricing rules and regulations in key countries and details of how you can get further advice from Grant Thornton specialists who can help with: • audit support – sophisticated economic arguments, research and databases can help defend transfer pricing policies before the tax authorities • documentation – using expert local knowledge to prepare country-specific documentation to satisfy local tax regulations • planning – the growth or restructuring of a company doing business internationally provides an opportunity to review transfer pricing and tax planning to minimise tax burdens • supply chain re-engineering – the critical analysis of the supply chain to gain operational efficiencies. For a more detailed discussion on any of the country specific transfer pricing rules, or for further assistance in addressing and resolving any intercompany transfer pricing issues, please contact the relevant country contact listed at the end of each article and at the back of this guide.
Contents 01 Australia 05 Canada 09 China 13 Czech Republic 17 France 21 Germany 25 Guernsey 29 Hungary 33 India 37 Ireland 41 Italy 45 Japan 49 Jersey 53 Korea 57 Netherlands 61 New Zealand 65 Portugal 69 Russia 73 Slovak Republic 77 Spain 81 Sweden 85 Taiwan 89 United Kingdom 93 United States 97 Contacts
Australia
Regulatory snapshot
Overview When did transfer pricing rules start? 1982 Level of TP Long standing and established
Global transfer pricing guide
More and more fiscal authorities continue to develop their transfer pricing laws. The principles are common, although interpretations differ from one tax authority to another. Compliance takes time and patience, and the demands and penalties from authorities are increasing. There is greater emphasis on examination and audit activity to encourage compliance and ignoring this issue is not an option for any well-run business. This international transfer pricing guide provides an overview of the different transfer pricing rules and regulations in key countries and details of how you can get further advice from Grant Thornton specialists who can help with: • audit support – sophisticated economic arguments, research and databases can help defend transfer pricing policies before the tax authorities • documentation – using expert local knowledge to prepare country-specific documentation to satisfy local tax regulations • planning – the growth or restructuring of a company doing business internationally provides an opportunity to review transfer pricing and tax planning to minimise tax burdens • supply chain re-engineering – the critical analysis of the supply chain to gain operational efficiencies. For a more detailed discussion on any of the country specific transfer pricing rules, or for further assistance in addressing and resolving any intercompany transfer pricing issues, please contact the relevant country contact listed at the end of each article and at the back of this guide.
Contents 01 Australia 05 Canada 09 China 13 Czech Republic 17 France 21 Germany 25 Guernsey 29 Hungary 33 India 37 Ireland 41 Italy 45 Japan 49 Jersey 53 Korea 57 Netherlands 61 New Zealand 65 Portugal 69 Russia 73 Slovak Republic 77 Spain 81 Sweden 85 Taiwan 89 United Kingdom 93 United States 97 Contacts
Australia
Regulatory snapshot
Overview When did transfer pricing rules start? 1982 Level of TP Long standing and established
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