The TJN Transfer Pricing conference organised in Helsinki , in partnership with Finland's KEPA and the Foreign Affairs ministry of Finland, was a resounding success. In essence, there was quite widespread agreement that the OECD's dominant so-called "Arm's Length" approach to transfer pricing -- which may have worked acceptably half a century ago when the global economy was a very different place -- is catastrophically broken today, and that real workable alternatives are available and already being put into practice.
The conference outcomes are summarised by John Christensen here, and the conference presentations, below.
- Opening remarks by Finland Minister Heidi Hautala
- The Indian Transfer Pricing System - Anita Kapur, Director-General of Income Tax
- Transfer Pricing: Alternative Methods of Taxation of Multinationals, Finland Minister for Foreign Affairs, Mr. Erkki Tuomioja. See also his closing remarks, here.
- The South African Transfer Pricing System, Gerdi van der Westhuysen, South African Revenue Service (SARS)
- Transfer Pricing in Latin America, Isaac Gonzalo Arias Esteban, International Cooperation and Taxation Director Inter American Center of Tax Administrations
- Rethinking the Source of the Arm's Length Transfer Pricing Problem, Ilan Benshalom, Hebrew University Faculty of Law.
- Formulary Apportionment— Myths and Prospects, Reuven Avi-Yonah & Ilan Benshalom
- International Transfer Pricing Abuse: Sizing the Problem, James Henry
- Transfer Pricing: Alternative Approaches / Sub Saharan Africa, Joseph H. Guttentag, International Senior Lawyers' project
- Bananas: the case of Ecuador, Juan Carlos Campuzano S. Servicio de Rentas Internas, Ecuador
- Transfer Pricing in Nigeria, Julius Bamidele, Director (Oil and Gas), FIRS, Nigeria
- Taxation of Multinational Financial Institutions Using Formulary Apportionment to Reflect Economic Reality, Kerrie Sadiq
- Transfer Pricing - the Brazilian case - Marcos Aurélio Pereira Valadao (with additional text here.)
- Meeting the Challenges of Transfer Pricing, Marlies de Ruiter, Head of Tax Treaty, Transfer Pricing, Fin. Transactions, OECD, more text here.
- SAB Miller: what happened next. Martin Hearson, ActionAid. Original report here.
- Combined Reporting with Formulary Apportionment: The Transfer Pricing System of the US States, Michael J. McIntyre Professor of Law, TJN Senior Adviser, Wayne State University
- Future of Taxing Multinational Corporations: Transfer pricing issues in Central America, Ricardo Barrientos
- Country-by-country reporting and transfer mispricing, Richard Murphy, Tax Research
- The Common Consolidated Corporate Tax Base (CCCTB) in Europe, Prof. Sol Picciotto, TJN Senior Adviser
- Brazilian Transfer Pricing – A Practical Approach Could this be a Model for Developing Countries? Tatiana Falcao, IBFD
- The Role of Finland in promoting international tax co-operation. Tuire Santamäki-Vuori, State Secretary, Ministry of Finance
- Indian Transfer Pricing System, Vikram Vijayaraghavan, SAPR Associates, Chennai
- China’s transfer pricing system, Zhang Ying, State Administration of Taxation of People’s Republic of China
For David Spencer's long introductory piece ahead of the conference, summarising criticisms of dominant OECD methods, click here.