The Tax Justice Network has just published a blog on a new EU report on transfer pricing and developing countries.
As they point out, from the outset the report is covered in warning signs about its likely failure to be impartial since the title page carries the following logo:
Why the problem? TJN explains in depth, and I warmly recommend their blog. But I'll add these issues:
a) PWC are emphatically opposed to country-by-country reporting which has greatest prospect of providing developing countries with the risk assessment data they need to determine which transfer pricing cases to pick. You can't promote good transfer pricing practice and oppose the availability of data to make it possible.
b) PWC act for the corporates doing much of the abuse.
c) PWC are found in all the world's major tax havens - where much of the ill gotten gains of abuse are likely to be stashed.
To put it another way - PWC are completely conflicted on this issue meaning anything they write lacks any objective credibility. And given that this issue is so big that's a disaster when the resources dedicated to this issue are so limited.
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By her own admission she hasn’t even read the report (frankly I’m a bit surprised she decided to comment without at least reading it- slightly tabloidesque in my view).
By your own admission pwc are present in the territories the report covers and therefore are arguably in the best position to commentate on the rules locally
Perhaps you would prefer them not to publish anything and then everyone could rant about them not participating in the debate and colluding to keep the tp position secret?
Damned if they do and damned if they don’t in the eyes of some
a) I think the author was male
b) So you reckon the Mafia should write a review of criminal law? That’s what your logic implies
I am simply saying there is better expertise elsewhere
Was it that hard to get the point of what I was saying?
Re (b) – who would you suggest with the necessary expertise in Transfer Pricing?
The comment about the OECD TP rules being designed for rich countries and the Big 4 is totally discredited by current facts, probably deliberately omitted by the author.
TJN has already recommended some – in the piece and there are others
What facts? Please relate
Make them facts
And make them of general application
Start with the number fo successful transfer pricing challenges ever raised by African states please
Only name they mentioned was Washington attorney (and ex-PWC transfer pricing partner) Mike Durst – perhaps because he mentioned formulary apportionment, and how exciting must have that have been. Anyhow, there is little to apply the label of expert on him above many others.
On the factual side, the UN Committee of Tax Experts has been working since 2009 on developing a practical manual for transfer pricing issues faced by developing countries. Two drafts have already been issued and it is likely that the manual will be finalized in 2012,
The critical issue is that the UN has endorsed the arms-legnth principle, similar to the OECD TP Guidelines, and has effectively followed the OECD guidelines, with some practical exceptions.
I didn’t see any mention of CBC reporting in the the draft of May this year – maybe they didn’t receive such comment after last years draft.
The old Denny Willis (see Wikipedia) and Quorn Quartet routine “The Fox Has Left Its Lair” is available on youtube and there are several choices. Yes, I saw it live. It reminds me very much of the way The Big Four seem to operate these days. Tally Ho!
Amused – see here http://www.youtube.com/watch?v=8WRdJ5wBXpo
[…] Tax Research UK has covered this blog – and added this: a) PWC are emphatically opposed to country-by-country reporting which […]
Where is the better expertise then? If it was better why werent they commissioned to write the review?
Because of regulatory capture
I’m sure you’re aware of it
If not – please acquaint yourself with it
Regulatory capture is the last line of defense for someone without a decent answer – you might just as well come up with a conspiracy theory. Got a source for pwc saying they are opposed to country by country reporting by the way? Rather than something which merely states that they will follow whatever the ifrs rules state?
Regulatory capture is fact
And the whole PWC total tax contribution framework is in part an attempt to undermine country-by-country reporting – as they have said often in meetings and in public
Pwc have said in meetings that their total tax contribution is an attempt to undermine country by country reporting – come on Richard you can do better than that. Any written sources you can link to or is it all heresay ?
http://www.taxjournal.com/tj/articles/tax-reporting-campaign-reflects-lack-public-trust-says-pwc2411
and
http://www.pwc.ch/de/dyn_output.html?content.cdid=24604&content.vcname=newsletter_seite&collectionpageid=559&backLink=http%3A%2F%2Fwww.pwc.ch%2Fde%2Fpublikationen%2Fnewsletter%2Ftaxenews.html that makes clear they propose an alternative
and http://www.financialtaskforce.org/wp-content/uploads/2009/10/Horacio_Pena-Country-by-Country-Reporting.pdf again showing they oppose
It wasn’t hard to find
Why not try google sometime? “pwc country by country reporting” achieved that
So respectfully – don’t waste my time
The first article dosent say anything about cbyc being bad at all
The second one highlights some potential issues and raises a possible alternative – clearly you think any debate around the subject and the issues involved is a bad thing
The third one is 2 years old and whilst it reads more negatively about cbyc it does still at least make the point that transparency is the goal everyone should be aiming for
The ‘alternative’ is designed to kill CBC – to which it is a political response intended to prove companies should pay less, not more, tax
You asked for evidence
I gave it
Unless you can be bothered to engage please don’t bother to comment again. You’re beginning to look very like a troll
I thought CBC reporting was intended to assist developing countries identify which TP cases they should be investigating.
Amongst many other things, yes
But one amongst many, let’s be clear
Your first post mentioned that pwc had explicitly said this in meetings- can you recall which pwc representatives said it? Just interested as from your links it appears that different pwc offices (in different countries) seem to take a slightly different line.
I’m not a troll unless your definition of one is someone who is interested in the evidence behind the stories etc rather than someone who just blindly believes everything printed
Susan Symons drives this intiative