Transfer Pricing. U.S. Transfer Pricing Experience. Aydin Hayri, Partner Deloitte Tax LLP, Washington DC
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1 Transfer Pricing. U.S. Transfer Pricing Experience Aydin Hayri, Partner Deloitte Tax LLP, Washington DC December 19, 2006 Ritz Carlton Hotel - Istanbul
2 History of the US Rules Legislation (tax code adopted in 1928): In any case of two or more businesses owned or controlled by the same interests, the Secretary may allocate income among them, if he determines that such allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such businesses. First Regulations (1968) Allowed only traditional methods with strict hierarchy More Legislation (1986) In the case of sale or license of intangible property, the income with respect to such transfer or license shall be commensurate with the income attributable to the intangible. Revised Regulations (1994) Introduced, profit-based methods, best method rule, economic comparability standards New/Proposed Regulations for Services and Cost Sharing (2006)
3 Interesting Court Cases Hospital Corp. of America US parent Co negotiated a management contract for a Saudi hospital. The contract was eventually signed by a Cayman Islands subsidiary Taxpayer position: This is the transfer of a business opportunity, not property Government position: Parent company transferred valuable property without payment Bausch & Lomb, Inc. US parent Co sold intangibles related to contact lenses to an Irish subsidiary and began purchasing contact lenses from the Irish subsidiary. Taxpayer position: Intangible sale and lens purchases are separate transactions conducted at arm s length prices Government position: Economic substance of the transaction is one of contract manufacturing, Irish sub should earn a limited contract manufacturing return
4 Interesting Court Cases GlaxoSmithKine UK parent company licensed the patents and trademarks for a successful drug to its US subsidiary. The US company was responsible for the US market sales Taxpayer position: Royalty rate leaves the US company with a fair distributor return Government position: Drug s success was related to the US marketing intangibles developed by the US distributor E 1 Du Pont de Nemours & Co US parent sold products through a Swiss sub that functioned as a distributor for European customers. Taxpayer position: Sold products at prices it would have sold to independent distributors Government position: Swiss sub had more limited functions than independent distributors and should earn proportionately lower margins
5 Inbound Planning for Operations in the US: Decide who will pay for the start-up expenses Decide who will fund intangible-related and critical business expenses Use a transfer pricing policy that you can easily implement and test Assess audit risk and penalty exposure to select an appropriate level of documentation Consider an advanced pricing agreement for certainty
6 Transfer pricing policies for US multinationals: Centralized approach: Parent company owns all important intangibles Parent company acts as the global entrepreneur Local subsidiaries function as distributors or contract manufacturers Regional approach: Parent company shares important intangibles with a regional HQ companies (generally located in tax-advantaged jurisdictions) Regional HQ company acts as the regional entrepreneur Local subsidiaries function as distributors or contract manufacturers Decentralized approach: Local subsidiaries may own intangibles, or license intangibles from the parent company and act as entrepreneurs for their local market They pay royalties and management fees to the parent company
7 Local transfer pricing compliance approach: Centralized and regional approach: Parent company typically has a global / regional transfer pricing policy and a global / regional report supporting the policy Global policy may need to be modified to be in compliance with local rules Local documentation may need to use different methods and data, but should be consistent with the global report Decentralized approach: There may be existing documentation relevant for certain aspects of the local operations that may be leveraged for local documentation purposes
8 Inbound Transfer Pricing: Planning -- decide what you want to do: What are your local business and treasury goals? Are they consistent with your company s global goals? Who are affected by the reported legal entity profitability? Evaluate your exposure and opportunities What are your controlled transactions? What is the current transfer pricing policy? What are your recent profitability trends? Leverage existing work within your global organization: Avoids duplication of effort Ensures consistency with your global policy and compliance models Scope out the work needed: All companies require a different level of transfer pricing planning and compliance effort
9 Outbound Transfer Pricing: Planning: What are your future growth areas? Where do you want to have cash and income? Do you use legal entity profitability for management and executive compensation purposes? If yes, can you change it? Do you want to have a central or regional entrepreneur in your international structure? How do you fund development and growth in new markets? Where is the best location for your intellectual property? Evaluate your exposure and opportunities: What are your controlled transactions? Do you need to charge royalties and management fees? What are the current transfer pricing policies? What are the recent profitability trends for your foreign affiliates?
10 Outbound Transfer Pricing (continued): Leverage existing work: Have you commissioned studies in local jurisdictions? Scope out the work: Use our Global Strategy Matrix and other information to important jurisdictions for documentation Explore the possibility of using a Master File approach
11 Conclusion: Transfer pricing is different from other tax work: Linked to business and treasury considerations Requires global coordination Presents more ambiguity as it follows economic principles Develop a viable plan for the transfer pricing planning, compliance, and controversy Periodically review your plan to stay ahead of the global changes
12 Dr. Aydın Hayri Partner Transfer Pricing Economist Deloitte Tax LLP Washington D.C. U.S.A. Phone : Fax : ahayri@deloitte.com
13 Deloitte Turkey Member of Deloitte Touche Tohmatsu
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