Transfer pricing and tax-effective supply chain managementSurvey after survey, transfer pricing is rated the most important tax issue facing multinationals. Transfer pricing affects the entire supply chain—from research and development, to manufacturing, marketing, distribution and after-sales service. Not surprisingly, tax directors confirm in our bi-annual global surveys that it is their most important concern. - Tax-effective Supply Chain Management
All over the world, enterprises are redesigning functions, implementing new structures and re-engineering flows of goods and services to reduce costs and improve business processes. Thinking about tax issues up-front can lead to the optimal supply chain structure. To address the issues that arise from supply chain reconfiguration, Ernst & Young offers clients a multidisciplinary TESCM team, bringing together specialists in transfer pricing, direct and indirect tax, customs, accounting and law. - Transfer Pricing Planning
Changing a business structure presents a perfect opportunity to carefully review transfer-pricing methods and adopt the optimal model. But even when a structure stays the same, advance planning can reduce the risk of double taxation. - Controversy Management
As fiscal authorities become more aggressive in applying their transfer pricing regimes, disputes are bound to arise. To fend off challenges, Ernst & Young pioneered the Advance Pricing Agreement process, concluding the first APA in 1990 and, since then, completing more APAs than any other firm. But often jurisdictions that are not party to an APA compete over the same tax dollars, leading to a significant risk of double taxation. For these situations, Ernst & Young's Controversy Management service offerings include litigation support, tax audit management and assistance in handling Competent Authority negotiations. - Documentation
An increasing number of countries now impose transfer pricing documentation requirements, most of which can be onerous for affected businesses. Using finely tuned methods to efficiently document transfer-pricing policies, dedicated specialists—including economists and tax professionals—can provide an integrated, multi-country approach to meeting documentation obligations.
Learn more about our Transfer Pricing and Tax Controversy services. | The CRA wants a piece of the $1.5 trillion transfer pricing pie Transfer pricing transactions between Canadian companies and their related parties outside of Canada are valued at more than $1.5 trillion annually. With transfer pricing rules essentially dictating how much of a company’s profit will remain in each country, it’s no wonder the CRA and other global tax authorities are focused on raising revenues through taxation. |
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