Growth in Transfer Pricing Enforcement Will Force Analysts to Rely More Heavily on Asian Financial Statements

International Transfer Pricing Journal, No. 6, 2008

Posted: 12 Dec 2008 Last revised: 20 May 2012

See all articles by Jamal Hejazi

Jamal Hejazi

Gowling Lafleur Henderson LLP - Transfer Pricing and Competent Authority

Date Written: December 12, 2008

Abstract

Tax practitioners, in performing their transfer pricing duties and determining the split in intercompany profits between related parties, will need to rely on third-party financial statements to determine an arm's length range attributable to various related parties. This article focuses on how performing working capital adjustments, while making economic sense in certain circumstances, is, practically speaking, not possible when using Asian comparable data.

Keywords: Transfer Pricing, China, Working Capital Adjustments

JEL Classification: B21

Suggested Citation

Hejazi, Jamal, Growth in Transfer Pricing Enforcement Will Force Analysts to Rely More Heavily on Asian Financial Statements (December 12, 2008). International Transfer Pricing Journal, No. 6, 2008, Available at SSRN: https://ssrn.com/abstract=1315448

Jamal Hejazi (Contact Author)

Gowling Lafleur Henderson LLP - Transfer Pricing and Competent Authority ( email )

180 Elgin Street
Ottawa, Ontario K1P 1C3
Canada

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