Page 52 - Strategic Tax Planning for Global Commerce & Investment
P. 52

Tax Benefits for U.S. Exporters


                            The potential penalties of non-compliance.


        Transfer Pricing Strategies


        In  an  effort  to  comply  with  the  transfer  pricing  rules  of  the
        jurisdictions where they conduct business, many businesses are taking
        different approaches to developing compliance strategies.

        1.  Do Nothing Approach


        One  approach  to  transfer  pricing  is  to  do  nothing.  This  is  the
        most  expensive  approach  since  the  taxing  authorities  have  the
        legal  tools  to  enforce  compliance  and,  in  times  when
        governments  are  in  need  to  raise  revenues  through  taxation,
        additional taxes through adjustments and penalties are the easier
        routes to raising additional revenues.


        2.  Comprehensive Analysis Approach

        This  is  the  most  sensible  and  least  expensive  approach.
        Management  needs  to  evaluate    all  costs,  risks  and  time
        involvement  and  design  an  approach  appropriate  to  the
        company  size,  nature  of  the  intercompany  transactions,
        worldwide  income  and,  in  general,  reviewing  the  company’s
        global structure and planning (discussed previously in section I).

        In developing and creating a team of decision makers to address
        and  resolve  the  transfer  pricing  issues  several  categories  of
        professionals are required, including the following:


                            Accountants
                            Attorneys
                            Computer programmers
                            Customs specialists

                                          44
   47   48   49   50   51   52   53   54   55   56   57