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
The information in any resource collected in this virtual library should
not be construed as legal advice or legal opinion on specific facts and should not be considered representative of the views of its authors, its sponsors, and/or ACC. These resources are not intended as a definitive statement on the subject addressed. Rather, they are intended to serve as a tool providing practical advice and references for the busy in-house practitioner and other readers.