APAs: an efficient vehicle for the auto industry
September 28, 2007
By Rolf Heinrich (Germany), Andrew Hickman (UK), Pascal Luquet (France) and Steven Tseng (China) of KPMG
By its nature, transfer pricing involves compliance with the rules of at least two tax jurisdictions. Complex supply chains can lead to the involvement of an even larger number of tax jurisdictions an automotive original equipment manufacturer (OEM) in France might buy parts from affiliated suppliers in Germany and China, licence technology from its parent company in Japan, and sell finished goods to an affiliated distributor in the UK. As a result of increased transfer-pricing compliance requirements and enforcement initiatives by tax authorities around the globe, taxpayers are faced with the complicated challenge of complying with often very different local rules and expectations from uncoordinated tax authorities, and responding to audits that could be done at different times.

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