Page: 94
Author: PwC TP
Release date: October 2009
Aswe all know, transfer pricing results in uncertain tax positions. Multi-national companies face the challenge of meeting the competingdemands of increasingly combative tax authorities and stakeholders whoseek certainty. The present economic situation has also heightened thechallenges that multi-nationals face.
What follows arearticles outlining new developments which will provide greater insightsand strategies in meeting the increased transfer pricing challengesduring these recessionary times including:
- the taxation of permanent establishments;
- business restructuring;
- implications of IFRS on cost sharing arrangements;
- as well as providing insights from India, China, Latin America and Eastern Europe perspectives.