KPMG has released a publication on transfer pricing controversies, highlighting how tax authorities worldwide are relying on specific "red flags" to tighten their enforcement and audit efforts.
The publication, "A Meeting of Minds - Resolving Transfer Pricing Controversies," discusses the warning signs that tax authorities look for when they launch an investigation. They include unusually high profits or losses in a group company, sharp changes in profitability from prior years, corporate restructurings involving closures or reductions in operations, significant inter-company management fees, dealings with a group company in a tax haven, and location in a low-cost country.
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