UK
will lead a survey into the practicality of global transfer pricing guidelines,
which is expected to enhance the understanding of transfer pricing as well as
offer new international operational guidelines for tax administrations and
taxpayers.
The
survey would have links to the work on transfer pricing by the OECD, a top
official of UK's HMRC stated at the recently held 11th Annual Tax Planning
Strategies meeting in Paris.
The
survey is expected to bring out a greater reliance on integrated documentation
systems that have been effective in rooting out key TP issues. It would also
help to simplify transfer pricing and allow taxpayers to share more information
with the authorities. The survey would also help tax administrations to rely
more on economists to decide whether a transfer pricing case was worth following
up as such disputes are time consuming and expensive operations.
Considering that tax authorities have lost a lot of TP cases, there is a
movement amongst tax authorities like the IRS to allow economists play a bigger
role which could help to decide whether a case is actionable.
It
may be recalled that recently the CBDT on the directions of the Supreme Court
issued official instructions for assessing officers and Transfer Pricing Oficers
to seek the opinion of technical experts in cases involving complex issues of
technical nature and substantial revenue.
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