Article: Managing transfer pricing audit risks

Transfer pricing continues to be the number one international tax concern of multinational enterprises (MNE), according to a 2001 Ernst & Young LLP biennial survey of more than 800 tax and finance directors. Interviews with various revenue authorities around the globe indicate that tax authorities also view transfer pricing as a top audit issue, scrutinizing MNEs' pricing for intercompany transactions to make sure the arm's length standard is followed.

As MNEs grow and use advanced communications and management information systems, the volume of intercompany, cross-border transactions has increased, along with the uncertainty of the tax treatment for such transactions. This uncertainty ...

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