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EY’s 2013 global transfer pricing survey, “Navigating the choppy waters of international tax”, leaves very little doubt that companies having important intercompany transactions across various different countries are struggling to meet their heightened obligations in a rapidly changing world. It is likely that the current environment will remain difficult for the next few years and those companies should take some steps to prepare.
Recent OECD developments, such as the BEPS project, the White Paper on Transfer Pricing and the OECD Intangibles Discus-sion Draft, indicate that Tax Authorities around the Globe will increasingly wish to review transfer pricing based on the totality of intercompany transactions and not simply on a transaction by transaction basis any longer...
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