This report addresses the practical administration of transfer pricing programmes
by tax administrations. Technical analysis of how transfer prices should be computed
in accordance with the arm’s length principle is outside the scope of this report.
Instead the report focuses on the practical experiences of a number of FTA member
countries and some non-member countries. The report discusses ways in which the management
of transfer pricing programmes can be optimised, so that transfer pricing audits and
enquiries are conducted efficiently and in a timely manner, for the benefit of MNEs
and tax administrations alike. It is concerned with the practical steps tax administrations
need to take to correctly identify transfer pricing cases that merit audit or enquiry
and then to progress those cases to as early a conclusion as possible.