Customs transfer pricing: the problem with branches
April 04, 2008
Kim Jarrett and Mark Cormack of KPMG New Zealand contrast the tax authorities’ divergent approaches in Australia and New Zealand
The taxation of branches (permanent establishments) is a complex and controversial area, and the global consensus at the OECD level has been a long time coming. In practice, we are seeing taxpayers continue to come adrift in this area of tax law. The taxation of permanent establishments has been the subject of debate for many years and the recent OECD reports on permanent establishments are intended to support global consistency in this area.
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