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World in Transition: Transfer Pricing Implications of Complex Supply Chains

World in Transition: Complex Supply Chains

Transfer pricing around corporate supply chains has become increasingly complex and closely scrutinized in recent years. This new publication from KPMG’s Global Transfer Pricing Services, A World in Transition: Managing the Transfer Pricing Implications of Complex Supply Chains, focuses on three discrete types of supply chain issues.


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Transfer pricing implications of complex supply chains

Part one discusses the implications of the new Organisation for Economic Co-operation and Development (OECD) Guidelines on Business Restructuring. This section includes specific country perspectives on business restructuring concepts from: Australia, Belgium, Canada, China, Denmark, France, Germany, Italy, Japan, the Netherlands, Spain, the United States and the United Kingdom.


The second part focuses on a few selected issues that arise in many multinational enterprise’s (MNEs) supply chains. 


The last section of this publication discusses controversy, including a discussion of two new tools to help taxpayers resolve controversy—accelerated competent authority procedures (ACAP) and binding arbitration—as well as a discussion on navigating transfer pricing controversy in India. The section looks at the rapid growth of advance pricing agreements (APAs) in Asia and includes APA- statistics in Australia, China, Japan and Korea. Finally, it includes a discussion of two court cases that have significant implications for supply chain management and restructuring—the General Electric case in Canada and the Veritas case in the United States.

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