The reassessment of the transfer pricing policy of a multinational enterprise results in principle in double taxation. Indeed, the amount reassessed by a State at the level of an affiliated company has already been taxed by another State at the level of the other affiliated company party to the reassessed transaction; the same income is therefore taxed twice. A transfer pricing reassessment can also have a withholding tax impact: in certain countries (such as France), the amount reassessed characterizes a deemed distribution of profit subject (depending on the tax treaty applicable) to a withholding tax.
Transfer pricing reassessment can therefore have significant tax impacts.
Region:
Algeria
,
Austria
,
Belgium
,
Brazil
,
Bulgaria
,
China
,
Croatia
,
Czech Republic
,
France
,
Germany
,
India
,
Italy
,
Japan
,
Netherlands
,
Poland
,
Portugal
,
Romania
,
Russia
,
Serbia
,
Slovakia
,
Slovenia
,
Spain
,
Switzerland
,
United Kingdom
,
United States
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