The Emergence of a European Dimension for Transfer Pricing
14 September 2006
By Pim Fris and Sébastien Gonnet
Over the last decade, transfer pricing has risen to a prominent place on the agenda of both multinational enterprises (MNEs) and European Ministers of Finance. However, in spite of the extended regulatory framework, increased knowledge, and better tools to solve the transfer pricing equation, Europe has not seen major improvements for reconciling MNEs and governments on the issue of transfer pricing and the elimination of double-taxation. In this article, published in Euromoney Yearbooks' Transfer Pricing Review 2006/07, NERA Special Consultant Pim Fris and Senior Consultant Sébastien Gonnet observe that, in light of recent developments -- including the EU Commission Code of Conduct on Transfer Pricing and debates within the OECD about the Transfer Pricing Guidelines -- to overcome these problems, multinationals will need to use robust economic analyses to develop policies that are consistent and transparent.
