It's complicated.  Depends on the nature of the entities and the 
relationship between them, the nature of the activities, and the 
particular countries and laws in question.  Related entities are subject 
to transfer pricing laws in various combinations of jurisdictions, 
countries like the United States tax worldwise, not just U.S.-based 
income, things like hazardous waste are subject to a recordkeeping trail 
wherever you may ship them, etc., etc.

The landscape changes over time as well, as countries try to grab tax 
money from overseas operations (there was just a big flap over Apple 
parking money in an Irish subsidiary, and Congresss is looking for ways 
to get at that money right now), and as they re-define things like 
"doing business" within a jurisdiction.  The recent flap over sales 
taxes on internet-based sales is illustrative of that -- states are 
re-defining what constitutes "doing business" in them so they can tax 
entities that have no physical presence at all in them.

And of course, many of these records end up on computer systems 
co-mingled with records from other countries and other related entities, 
and you may not be able to parse them out on a local basis anyway.

The upshot of it all is that for some of your records, a locally-based 
retention schedule works, and for others it doesn't; and which is the 
case depends on a lot of factors that will vary from organization
> s..."
>
>   I'd probably be inclined to at least ask the question of whatever legal
> team is available whether compliance would be required even if there are
> separate legal entities involved.  For example, I know of a company in
> Scotland which determined that it should comply with Sarbanes-Oxley in all
> of their legal entities, even though the vast majority of them did not "do
> business" in the United States.  I guess it's a matter of risk analysis,
> once you've defined the applicable legislation.
>
>

-- 
Best regards,

John
John Montaña
Montaña & Associates
29 Parsons Road
Landenberg Pennsylvania 19350
610-255-1588
484-653-8422 mobile
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www.montana-associates.com
twitter: @johncmontana




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