Post date: March 23, 2001 — 4:30 p.m.
Beginning Monday, March 26, the Harvard Law School International Tax Program will host a weeklong conference featuring officials from fifteen countries to discuss international transfer-pricing rules. The conference—co-sponsored by the Office of Overseas Operations and Tax Administration Advisory Services, and the Internal Revenue Service—seeks to assist foreign government tax officials drafting transfer-pricing rules and conducting transfer-pricing audits for multinational corporations.
“On a revenue basis, this is the most important international issue facing tax officials,” said Visiting Professor Eric M. Zolt, Director of the International Tax Program.
Transfer-pricing rules govern the price for transactions between related parties operating in different tax jurisdictions. “Think about General Motors selling cars in Brazil through its wholly-owned subsidiary. If the tax rate is lower in Brazil than the United States, then GM would have an incentive to charge the subsidiary less for the car and recognize the bulk of profits in Brazil,” explained Zolt.
Richard Ainsworth, Deputy Director of the International Tax Program, along with Kathy Bellamy, Senior Competent Authority Analyst for the IRS, and Michael Picariello, an IRS Technical Adviser, will lead discussions on the practice and theory of making and defending transfer price adjustments.
For more information on the conference, please visit the International Tax Program web site.