| Titre : |
Transfer pricing and developing countries : Final report |
| Type de document : |
document électronique |
| Auteurs : |
EuropeAid, Auteur |
| Editeur : |
Commission européenne |
| Année de publication : |
2011 |
| Autre Editeur : |
PWC |
| Importance : |
119 p |
| Langues : |
Anglais (eng) |
| Catégories : |
Fiscalité
Développement économique
|
| Tags : |
Prix de transfert Pays en développement Fiscalité Entreprises transnationales IDE Politique de développement UE |
| Résumé : |
(…) Several international organisations work actively on the provision of guidance in the area of TP, and some of them have particularly addressed the needs of developing countries. The Organisation for Economic Cooperation and Development („OECD?) has made considerable efforts to establish common ground in TP matters based on the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations („OECD Guidelines?). The United Nations („UN?) published new working drafts of its envisaged United Nations Transfer Pricing Practical Manual for Developing Countries („TP Manual?) on 31 May 2011, which are concerned with the practical implementation of TP rules in accordance with the arm?s length principle. With respect to international organisations, the importance of platforms for tax administrations must be highlighted, as they help foster cooperation and the exchange of best practices, also in the area of TP.
This report provides an overview on the possibilities for adopting and implementing TP legislation in developing countries and identifies possible ways to support developing countries with regard to its enactment. In order to carry out the study, we focused on four countries, which were selected by the EC. These countries are Ghana, Honduras, Kenya and Vietnam („selected countries?) and are all in different stages with regard to TP legislation. While Kenya and Vietnam have some kind of specific TP legislation in place, Honduras is about to adopt TP legislation shortly and Ghana currently has no TP-specific framework in place. (…)
Both the selected countries and developing countries in general to a large extent require technical assistance to build up TP expertise. We emphasise that there is a strong need for long-term assistance and ongoing cooperation on an international scale. The donor support initiatives should eventually aim at lifting the TP legislation and its application in developing countries to a common international standard. In our opinion, this is vital to reduce economic uncertainty and foster investment and growth. It is important to understand that TP reform should not be done under the guise of anti-abuse legislation but rather aim at improving the existing rules on corporate income taxation. The majority of taxpayers want to comply with local TP requirements in developing countries, and seek guidance on how to apply appropriate remuneration for related-party transactions to reduce tax risks.
|
| En ligne : |
http://ec.europa.eu/europeaid/what/economic-support/documents/transfer-pricing-s [...] |
Transfer pricing and developing countries : Final report [document électronique] / EuropeAid, Auteur . - [S.l.] : Commission européenne : [S.l.] : PWC, 2011 . - 119 p. Langues : Anglais ( eng)
| Catégories : |
Fiscalité
Développement économique
|
| Tags : |
Prix de transfert Pays en développement Fiscalité Entreprises transnationales IDE Politique de développement UE |
| Résumé : |
(…) Several international organisations work actively on the provision of guidance in the area of TP, and some of them have particularly addressed the needs of developing countries. The Organisation for Economic Cooperation and Development („OECD?) has made considerable efforts to establish common ground in TP matters based on the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations („OECD Guidelines?). The United Nations („UN?) published new working drafts of its envisaged United Nations Transfer Pricing Practical Manual for Developing Countries („TP Manual?) on 31 May 2011, which are concerned with the practical implementation of TP rules in accordance with the arm?s length principle. With respect to international organisations, the importance of platforms for tax administrations must be highlighted, as they help foster cooperation and the exchange of best practices, also in the area of TP.
This report provides an overview on the possibilities for adopting and implementing TP legislation in developing countries and identifies possible ways to support developing countries with regard to its enactment. In order to carry out the study, we focused on four countries, which were selected by the EC. These countries are Ghana, Honduras, Kenya and Vietnam („selected countries?) and are all in different stages with regard to TP legislation. While Kenya and Vietnam have some kind of specific TP legislation in place, Honduras is about to adopt TP legislation shortly and Ghana currently has no TP-specific framework in place. (…)
Both the selected countries and developing countries in general to a large extent require technical assistance to build up TP expertise. We emphasise that there is a strong need for long-term assistance and ongoing cooperation on an international scale. The donor support initiatives should eventually aim at lifting the TP legislation and its application in developing countries to a common international standard. In our opinion, this is vital to reduce economic uncertainty and foster investment and growth. It is important to understand that TP reform should not be done under the guise of anti-abuse legislation but rather aim at improving the existing rules on corporate income taxation. The majority of taxpayers want to comply with local TP requirements in developing countries, and seek guidance on how to apply appropriate remuneration for related-party transactions to reduce tax risks.
|
| En ligne : |
http://ec.europa.eu/europeaid/what/economic-support/documents/transfer-pricing-s [...] |
|
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