Transfer Pricing Specialists in Demand

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The 3rd installment of the Ernst & Young LLP Transfer Pricing Survey suggests that the recruitment market for transfer pricing specialists looks rosy. Certainly the number of Transfer Pricing vacancies advertised around the world has increased in the past 12 months and experienced practitioners are able to relocate with relative ease from one jurisdiction to another.

I have detailed below are some excerpts from the EY survey that might be of interest to TP specialists and tax recruiters:

“Transfer pricing continues to be the most important international tax issue facing multinational enterprises,” said Bob Ackermann, Americas Leader, Transfer Pricing Services, Ernst & Young LLP. “The major theme that emerges from our survey is one of change; Change in approach from governments around the world, change in legislation and change in attitude. The impact is enormous as MNE’s work to meet their transfer pricing obligations.”

In the two years since the previous survey, tax authorities around the world are better prepared and under more pressure to deliver revenue gains from their anti-tax-avoidance efforts. Key findings from the survey include:

Changing Environment: Countries such as China, Colombia, Israel and Turkey are entering the transfer-pricing enforcement field, while countries such as Canada, New Zealand and the UK are stepping up resources, levels of sophistication and intense focus in their transfer-pricing efforts.

Risk Management: A large number of countries stated that they will focus on transaction flows with lower tax jurisdictions. Almost all of the European countries surveyed made the point that these types of transactions were on their ‘hit list.’

Enhanced Analytical Approaches: There is evidence of increasing sophistication in data gathering by tax authorities to augment their enforcement efforts. Argentina, for example, is cross-matching data and Brazil has invested in new software.

“Companies today must assume that tax authorities everywhere will have a complete picture of their global tax position, and that any steps they take in one country will have implications across their entire operation,” said John Hobster, Global Markets Leader – Transfer Pricing Services for Ernst & Young. “While we’re seeing some apparent convergence among these authorities around high-level transfer-pricing stances, such as acceptance of the OECD’s ‘arm’s length’ principle, authorities in different countries are diverging in interpretation and implementation of these principles. This can come as a shock to multinational companies and hinder the resolution of bilateral disputes.”


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