The Best Transfer Pricing Defense Is a Good Offense: Using a Bilateral U.S. APA to Benchmark Reasonable Results
Sep 04, 2014
From the KPMG TaxWatch
Steven Wrappe from KPMG LLP in the United States and Koichiro Fujimori from KPMG Tax Corp. in Japan recommend in this article using bilateral advance pricing agreements with Japan--which has emerged as a dominant U.S. partner in APAs--as a benchmark in transfer pricing with other tax jurisdictions.
The authors note that this approach may be particularly advisable in light of the potential greater exposure to transfer pricing adjustments that may result from the Organisation of Economic Co-operation and Development's Base Erosion and Profit Shifting (BEPS) Action Plan, specifically the new country-by-country reporting and transfer pricing documentation guidelines.
Read The Best Transfer Pricing Defense Is a Good Offense: Using Bilateral U.S. APA to Benchmark Reasonable Results, which appeared in the September 4, 2014 issue of Tax Management Transfer Pricing Report™ and appears here with the publisher's permission.