WorldTrade Executive (WTE), a Thomson Reuters
brand, has released its ninth edition of Global Transfer Pricing Solutions
, providing an important update concerning worldwide transfer pricing regimes. Regimes are constantly in flux, but they can have a critical impact on the profitability of business.
"There are significant transfer price regulatory developments under way in Latin America, particularly in Colombia, Brazil, Panama, and Peru," said Gary Brown, senior director of WTE, Thomson Reuters. "There are also important changes in Australia and China."
For example, through Law 1607 of December 26, 2012, the Colombian government approved a tax reform project that included modifications to the transfer pricing rules in force since 2004. In the law, taxpayers will find new concepts related to transfer pricing such as thin capitalization, permanent establishments, non-corporate entities or arrangements, free trade zones, corporate restructurings, and advance pricing agreements rollbacks.
For maquiladoras in Mexico (manufacturing operations in free trade zones) transfer pricing interaction with other tax legislation can have severe repercussions. It can determine whether a maquiladora creates a permanent establishment for its foreign principal and also whether it qualifies for an income tax incentive.
The report points out that some countries follow OECD transfer pricing guidelines and others, such as Brazil, do not. There also are important initiatives underway to change OECD guidelines.
Global Transfer Pricing Solutions garners insights from experienced practitioners at international legal and accounting firms and senior international transfer pricing professionals at large multinational companies. The report's fifty-six articles offer full coverage of changes to major worldwide transfer pricing regimes with an in-depth analysis of steps needed to proactively manage transfer pricing.
Some of the topics covered include:
- Unwrapping the New Cost Sharing Regulations, by Rocco V. Femia, Mary W. Prosser, and Kathryn Morrison Sneade (Miller & Chevalier Chartered)
- Customs Valuation and Multinational Transfer Pricing: Can They Co-exist?, by Matthew Nolan (Arent Fox LLP)
- Maquiladora Transfer Pricing (and Related Issues), by Jaime Gonzalez-Bendiksen (BéndiksenLaw)
- Recent Developments in Latin American Transfer Pricing: A Roundtable Discussion, by Jeffrey S. Korenblatt (DLA Piper LLP)
- Transfer Pricing: The SAT's Paper and the Reality of Transfer Pricing in China, by Daniel Chan, Patrice Marceau, and Windson Li (DLA Piper, China)
- Japan Transfer Pricing: A Fresh Look at the Japan-US Bilateral APA Relationship, by Akio Miyamoto, Ryann Thomas, and Michael Polashek (PricewaterhouseCoopers, Tokyo)