Transfer, Pricing, OECD, Tax, Shared Service, Offshore
Impact on transfer pricing of OECD and tax treaties for shared service and offshore centers
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The taxation of offshore service delivery providers and their onshore marketing affiliates can have an impact on shared service centers, offshore captives and financial planning for foreign acquisitions of specialty service companies in the U.S.
and other OECD countries. The U.S. Treasury Department's publication, on November 15, 2006, of the latest U.S. Model Income Tax Treaty highlights the evolution of transfer pricing issues that now need to be addressed as part of due diligence in planning and structuring international service companies. Indirectly, transfer pricing can have an impact on outsourcing as well.
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