The application of any transfer pricing rule – and any
other tax rule – is normally attached to the condition
that there is real economic activity by the separate entities.
Thus, the definition and control of this condition has
a vital role for fighting tax evasion. The space between
obvious letterbox companies and large-scale factories is
vast. Nevertheless, there are indications that although
many countries do not permit letterbox companies on
paper, the reality is different.
In the Netherlands, for example, it is apparently enough
to register a company and have an address to be accepted
as a real company. Even if it is not that simple all the time,
it is often possible to engage in large-scale sales, etc. with
very little staff. With its tax privileges for holding companies,
Switzerland has attracted affiliates of all big commodity
multinationals and is now the biggest commodity
trading location in the world – even though it has almost
no commodities of its own. This is how large amounts of
money move to Switzerland and are no longer taxable in
the extraction countries; which sheds light on the problem
that, even if there is real economic activity in Switzerland,
it does not actually mirror the economic activity
in the different countries concerned. If the main business
is still in the extraction countries, it is inappropriate that
Switzerland gains a large part of the profits.