Page 7 of 7 Controversy & Disputes with Tax Authorities The Transfer Pricing Process allows you to resolve the following controversy issues: How to create supporting evidence of the current compensation to the local sales & marketing organization, in case no documentation has been created in the past? What is the sound business case for closing down activities in a specific country and will those arguments be valid for tax purposes as well, i.e. avoid substantial exit tax consequences? Did any transfer of business take place from the local organizations to the European sales force and/or would you describe the situation as relocation of roles and responsibilities? What are the arguments to justify your change in transfer pricing system you could extract from what is happening in your industry and how your competitors are revamping their business as well? What is the support from both an economic and a tax perspective to compensate the local sales representative on a cost-plus basis? How to organize and actively manage any potential transfer pricing disputes arising from your change to another transfer pricing system? How to defend upon controversy the loss reported by the sales subsidiaries in Europe, whereas the consolidated European results show a profit for 2006 (actual) and 2007 (budget)? How effectively align the timing of controversy between the various countries to mitigate the risk of double taxation in Europe, and to what extent are the EU Arbitration Convention and the tax treaty framework helpful?     << Start < Prev 1 2 3 4 5 6 7 Next > End >>