A new report from BNA Tax & Accounting on transfer pricing predicts that tax authorities in different countries will continue to closely scrutinize intercompany transactions across national borders and will begin simultaneous audits of several large companies intercompany prices this year.
After successfully cooperating last year on offshore matters through the Joint International Tax Shelter Information Centre, officials say they will continue sharing information and begin simultaneous transfer pricing audits in which two nations analyze a large companys intercompany prices at the same time. The Centre includes representatives from the tax authorities in the U.S., the U.K., Canada, Australia and Japan.
As governments search for revenues, officials have said that cross-border movement of profits to low- or no-tax jurisdictions are under review, said Transfer Pricing Report managing editor Rita McWilliams. Multinationals should make sure they are prepared to have several different jurisdictions consider their documentation together in 2010.
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