International Transfer Pricing - PwC

internationaltp

International

Transfer Pricing

2013/14

An easy to

use reference

guide covering

a range of

transfer pricing

issues in nearly

80 territories

worldwide.

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International

transfer pricing

2013/14

All information in this book, unless otherwise stated, is up to date as of 15 September 2012.

This publication has been prepared for general guidance on matters of interest only, and does not constitute professional

advice. You should not act upon the information contained in this publication without obtaining specific professional advice.

No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained

in this publication, and, to the extent permitted by law, PwC does do not accept or assume any liability, responsibility or duty

of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this

publication or for any decision based on it.

? 2013 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a

separate legal entity. Please see structure for further details.

Preface

It is my pleasure to present the 2013/14 edition of our International Transfer Pricing

book. There have continued to be significant changes in the area of transfer pricing

since our prior edition, with several new countries implementing either formal or

informal transfer pricing documentation requirements and significant regulatory

changes in many other countries over the past twelve months.

Part I of the book provides a general overview of the global approach to transfer

pricing issues. Part II is devoted to a summary survey of specific requirements of the

key countries with transfer pricing rules. This edition includes the addition of The

Sultanate of Oman.

We anticipate that this will be another eventful year during which the subject

of transfer pricing will continue to be at the centre of continuing controversy in

corridors of power and newspaper editor¡¯s offices around the world. A combination

of public debates on the ethics of tax planning, political and economic pressures, and

increasingly well trained tax examiners will all contribute to a continuing increase in

the number of transfer pricing disputes globally especially as an increasing number of

tax authorities attempt to enforce their transfer pricing rules more aggressively. It is

PwC¡¯s view that strategic dispute management (such as through dispute avoidance or

alternative resolution techniques) on a global basis will become increasingly crucial in

companies¡¯ efforts to sustain their global transfer pricing strategies.

We look forward to working with you in 2013 and beyond.

Best regards,

Garry Stone, Ph.D.

Global Transfer Pricing Leader

PwC (US)

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