Emerging Trends in Transfer Pricing

Dr Daniel N Erasmus 27 November 2023

Article published in SAIT, Tax Talk Magazine, Issue 103 November/ December 2023

Transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... (TP) disputes have always posed challenges to multinational enterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... (MNEsWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include...) and tax authorities. The interpretation and implementation of arm’s length principles, the backbone of TP regulations, have led to an increasing number of TP disputes across the globe. This article considers emerging trends, emphasising the critical role of TP expert witnesses in any TP dispute.

The significance of TP expert witnesses in TP disputes

A central theme in any TP dispute resolution process is the selection and preparation of a TP expert witness. Such an expert is often called upon to lend their expertise during the trial; however, their participation is required very early in the TP dispute process to aid in finding workable resolutions.

Selecting the right TP expert witness

The onus of proving the arm’s length price rests with the taxpayer. It is crucial to choose an expert who possesses the requisite technical knowledge and the capability to present findings credibly in a court environment. Whereas there are many TP specialists globally, only a handful have the experience to serve as an effective expert in such a setting. A list of key considerations in selection follows. >>> Click here to download the full article >>>

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Postgraduate Certificate – 6-month Course
Postgraduate Diploma – 1 Academic Year
Master (MSc) – 2 years (dissertation only if you have an existing PG-D from I/I/T/F)
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PROGRAMMES IN TRANSFER PRICING

Postgraduate Certificate – 6-month Course
Postgraduate Diploma – 1 Academic Year
Master (MSc) – 2 years (dissertation only if you have an existing PG-D from I/I/T/F)
Contact our Education Consultant, Ben Price, at tp@informaconnect.com or call him at +44 (0) 208 052 2710.

* All programmes are delivered by I/I/T/F Academy of Tax LawTax laws form the backbone of any nation’s revenue system, setting the rules that govern how individuals and corporations contribute financially to support government functions. These laws define the types of taxes, the applicable rates, and the regulations regarding payment and compliance. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public... and validated and certified by Middlesex University, London. InformaConnect Ltd is the programme partner.

Categories: South Africa, Transfer Pricing

Dr Daniel N Erasmus

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April/May 2015[1] Impact of FATCA on Cook Islands Entities[2] TABLE OF CONTENTS Background The key differences between FATCA and IGA Models 1 and 2

ATL-Editor 27 April 2015

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AFRICA: Sub-Saharan Africa and international arbitration – how does that work?

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ATL-Editor 29 August 2014

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*For clarity, the term Double Tax TreatyA Double Taxation AgreementA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and... (DTAA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and...), also known as a Double TaxationDouble Taxation occurs when the same income or financial transaction is taxed twice, typically in different jurisdictions. It can arise in two primary contexts: economic double taxation, where the same income is taxed twice in the hands of different taxpayers, and juridical double taxation, where the same taxpayer is taxed on the same income in more than one country. Double... Treaty (or a Tax TreatyA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and...), is an international

ATL-Editor 28 August 2024

S.Africa: Summary of the Davis Tax Committee’s BEPS Sub-committee General Report released December 2014

Summary of the Davis Tax Committee’s BEPSBEPS stands for "Base Erosion and Profit Shifting". BEPS refers to tax avoidance strategies used by multinational enterprises (MNEs) to exploit gaps and mismatches in the international tax system. By shifting profits from high-tax jurisdictions to low- or no-tax locations, MNEs reduce their overall tax burden, even if little to no economic activity occurs in the low-tax jurisdictions. These practices erode... Sub-committee General Report released December 2014 by Peter Dachs of ENS Introduction This note provides a summary of

ATL-Editor 26 February 2015

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Emerging Transfer Pricing Trends in Africa: Insights from Dr. Daniel Erasmus at the 13th Annual Africa TP Summit

In this insightful address at the 13th Annual Africa Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... Summit, Dr. Daniel N Erasmus explores the most pressing trends in transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... across Africa and developing regions.

ATL-Editor 10 October 2024

CHECK OUT THESE POSTGRADUATE PROGRAMMES IN INTERNATIONAL TAXATION AND TRANSFER PRICING:

PROGRAMMES IN INTERNATIONAL TAXATION

PROGRAMMES IN TRANSFER PRICING

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