The Finnish government moved quickly today to clarify figures released by the Parliament’s Audit Committee which stated that the Finnish exchequer lost up to $2 billion annually because of transfer mispricing.
Joe Andrus, head of the OECD’s transfer pricing unit, has told TPWeek that guarantee fees and credit ratings are an important issue for the OECD but it is not possible to say when a formal project on the topic might start until the final intangibles report is released.
Management fees present particular difficulties for taxpayers. Whenever an asset management service is performed by a resident of one jurisdiction for a recipient in another there are transfer pricing implications.
The OECD’s draft on the transfer pricing aspects of intangibles does not deal fully with all aspects of the project but official, Marlies de Ruiter, said these issues will be discussed at the next meeting in November.
The IRS is demanding $27 million from tech company Altera because it says the company wrongly booked employee stock-based compensation in the US where it is tax deductible.
Complex transfer pricing challenges are arising from the increasing number of joint ventures, particularly in the US, between multinational oil and shale gas exploration companies.
