Transfer pricing and tax-effective supply chain management - Ernst & Young - Global

Transfer pricing is the No. 1 tax issue for multinationals. So how do the rules differ from country to country? How has the economic crisis impacted them? We surveyed experts and tax authorities in 49 jurisdictions to find out.

Transfer pricing is a risk issue for multi-national enterprises (MNEs) when it comes to financial reporting. Transfer pricing audits are increasing and tax authorities are willing to impose adjustments and penalties. Ernst & Young's 2007-8 Transfer Pricing Survey (pdf, 2mb) covers 850 MNEs in 24 countries and summarizes their transfer pricing practices, perceptions and audit experiences and provides insight into how they are dealing with the economic, regulatory and fiscal changes taking place around the world.

The February 2009 version of Ernst & Young’s Transfer pricing global reference guide is now available. This guide is a comprehensive tool that is designed to help international tax executives to quickly identify the transfer pricing rules, practices, and approaches that have been adopted by over 45 countries. These various approaches must be understood in order to complete both compliance and planning activities.

Cross-border transactions are now a major focus for European tax authorities. They have observed the wave of business restructuring over the last decade and its impact on the tax base when a multinational enterprise integrates and rationalizes its European operations. How they deal with these issues is therefore of interest to tax directors responsible for these structures. Read more in this executive summary of Ernst & Young's survey (pdf, 586kb).

This publication is intended primarily for transfer pricing and tax professionals with responsibility for the transfer pricing arrangements and documentation within banks, asset management and insurance companies operating internationally. However, FSTP worldwide may also serve (pdf, 279kb) as a guide to consultants, tax practitioners and scholars with an interest in transfer pricing for financial services firms.