Transfer Pricing Regional Approach Urged by Sony Tax Director17 July 2005
Marc Lewis, Senior Director of Tax Planning at Sony Corporation, advises companies to consider a regional approach to transfer pricing in the Americas in the latest issue of Practical Latin American Tax Strategies.
Lewis notes that “in light of the sheer number of countries in this region with some form of transfer pricing requirements, a regional approach, rather than a country-by-country approach, may fit the profile of some multinational companies.”
A regional approach works best where 1) groups of countries in a region have similar transfer pricing requirements and 2) there is consistency in how an MNC operates from country to country.
Lewis argues that having a regional approach may help companies save time and money. Most transfer pricing studies contain the same basic components (i.e., industry analysis, functional and risk analysis, and economic analysis); therefore common components among studies means they are easier to generate and keep current.
Furthermore, having transfer pricing studies that “consistently” present a company’s profile and results can lead to a stronger transfer pricing audit defense. Today, tax authorities are cooperating more often and taxpayers cannot assume that a Mexican transfer pricing auditor could never get a copy of an Argentine or Venezuelan study.
Practical Latin American Tax Strategies is edited by PricewaterhouseCoopers and published by WorldTrade Executive, a leading provider of practical tax advisories, such as Practical U.S./International Tax Strategies, Practical Asian Tax Strategies, Practical Mexican Tax Strategies and Practical European Tax Strategies.
A sample of Practical Latin American Tax Strategies is available by contacting WorldTrade Executive, Inc., PO Box 761, Concord, MA 01742, (T) (978) 287-0301, (F) (978) 287-0302, .
Source: PrWeb
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