Since 1995, Ernst & Young has surveyed multinational enterprises (MNEs) on a range of international tax matters, with special emphasis on what continues to be the number one international tax issue of interest to them — transfer pricing.
The increased scope of our biennial transfer pricing research reflects:

• the intensely challenging economic climate
• the growing number of countries that devote attention to transfer pricing activities
• the increase in the number of countries introducing both documentation requirements and penalty rules
• the ever-increasing diversity of transfer pricing issues facing MNEs

Amid the challenges of a global economic downturn, many governments are sharpening their focus on compliance, enforcement and legislative approaches. We trust that you will continue to find our 2009 global transfer pricing survey, tax authority insights: perspectives, interpretations and regulatory changes a useful tool in navigating this increasingly complex and challenging environment.
The information presented in this survey was gathered by Ernst & Young transfer pricing professionals around the world. Where tax authorities were prepared formally to discuss their approaches with us, we conducted interviews with them; those interviews were supplemented by the insights of our transfer pricing leaders in the relevant jurisdictions. In other jurisdictions, our transfer pricing professionals provided insights garnered from their experience of dealing with (and/or recently working within) their local tax administrations.