Over the last several years, most major countries have strengthened their transfer pricing rules, often through documentation requirements and penalties, and have stepped up enforcement. One reason for the increased challenge to taxpayers on their transfer prices is that tax authorities view transfer pricing as a soft target. Because of the difficulty involved in proving that their transfer price is acceptable, companies might prefer to simply pay the additional tax rather than engage in a lengthy, complicated dispute. The risks associated with local tax authorities scrutinizing a companys transfer prices.
Requirements:
Multinational transfer pricing causes serious concern for various corporate stakeholders.
Students are required to select a foreign company and country as a home country and provide an in-depth discussion for potential concerns from the view-point of:
a. minority owners of a foreign affiliate,
b. foreign taxing authorities,
c. home-country taxing authorities,
d. foreign-subsidiary managers, and
e. headquarters managers.
