Transfer Pricing Audits: Treatment Of Intangibles By The Nigerian Tax naija247news.com - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from naija247news.com Daily Mail and Mail on Sunday newspapers.
Robert Johnson, Guillermo Noguera
The global engagement of a firm could range from none at all, to exporting and importing only, to exporting, importing and engaging in foreign direct investment. Research has shown that, for firms located in the US, the most globally engaged firms dominate both trade and investment. Bernard et al. (2009) find that multinational enterprises (MNEs) accounted for roughly 90% of US exports and imports of goods in 1993 and 2000. Bruner and Grimm (2019) find that MNEs accounted for roughly 90% of US exports and imports of selected services in 2011–2017. The dominance of MNEs in both trade and investment suggests that most international trade is associated with their global value chains (GVCs) and that the traditional notion of exports and imports representing transactions between producers and final consumers is in need of an update.
IEIM140100 - Overview
The International Compliance Assurance Programme (ICAP) is a voluntary programme facilitating multilateral engagements between Multinational Enterprise groups (MNE groups) and tax administrations. ICAP involves a high-level risk assessment of transfer pricing and permanent establishment risks and is designed to provide increased tax certainty for both MNE groups and tax administrations. Central to ICAP is the concept of open and transparent dialogue between the MNE group and the participating tax administrations.
ICAP provides MNE groups with an outcome letter that sets out how each participating tax administration views the level of risk for the years reviewed. An additional 2 years comfort may be provided as part of a roll forward period if the transactions are viewed as low risk. Whilst ICAP does not provide legal certainty, it does give an added level of comfort over the transactions considered within the risk assessment. As such ICAP is a resource efficie