Chapter 13 395
accessible website, in whole or in part.
Excerpted from Transfer Pricing in a Recession: What Companies Should Con-
sider (PricewaterhouseCoopers, 2009)
With rising unemployment comes reduced personal income taxes, and with re-
duced corporate profits come reduced corporate revenue. The global tax base has
decreased and probably will continue to shrink. Even in a recession, a discussion
by any politician of increased taxes is risky. More money is needed to keep fund-
A substantial increase in tax audits, including those focused on transfer pricing, is
expected. In addition to the increased number of audits expected globally, the dif-
ficulty and complexity of such audits are expected to increase as taxing authorities
continue to become more sophisticated and open to sharing taxpayer information.
table.
In such uncertain economic times, how should multinational companies approach
defending past transfer pricing policies including those established under advance
pricing agreements during robust economic times? How should companies pre-
quired supply chain modifications) will have significant implications for their abilities
to reduce costs and remain competitive.
From David D. Stewart, “Transfer Pricing Practitioners Find Challenges, Oppor-
is drawn from boom years, and you probably don’t want to benchmark your pric-
ing against that position or indeed you may not be able to,” Hasson said. “This
whole question of comparability has gotten a whole lot harder,” he added.
companies considering or in negotiations for an APA, Ossi explained that the
IRS’s APA office is open to a range of “techniques and refinements” employed in