Shiv Mahalingham (Duff & Phelps) answers a query on designing a compliant transfer pricing structure which is efficient from a tax arbitrage perspective.
Question
Is it possible to design a robust transfer pricing structure that is compliant with regulations yet still efficient from a tax arbitrage perspective?
Answer
While there are important commercial factors to bring to the surface the answer is ‘yes’ – as long as there are different effective tax rates in the jurisdictions in which companies operate and as long as economic substance supporting the transfer pricing structure is in place. This requires a proactive planning approach in contrast to a reactive documentation led approach to transfer pricing policy.
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Shiv Mahalingham (Duff & Phelps) answers a query on designing a compliant transfer pricing structure which is efficient from a tax arbitrage perspective.
Question
Is it possible to design a robust transfer pricing structure that is compliant with regulations yet still efficient from a tax arbitrage perspective?
Answer
While there are important commercial factors to bring to the surface the answer is ‘yes’ – as long as there are different effective tax rates in the jurisdictions in which companies operate and as long as economic substance supporting the transfer pricing structure is in place. This requires a proactive planning approach in contrast to a reactive documentation led approach to transfer pricing policy.
Recent case study
Many companies are responding to...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
