Paul Sutton (LCN Legal) and Philip de Homont (Nera Economic Consulting) set out a framework when considering the allocation of risks in transfer pricing.
In transfer pricing as in everyday life the existence and extent of contractual rights have a significant impact on the financial terms on which parties are willing to enter into transactions. A number of recent decisions in transfer pricing cases have reaffirmed the need for transfer pricing policies to be legally implemented through appropriate intercompany agreements in addition to their implementation in operational practice.
The OECD’s transfer pricing guidelines provide a framework for analysing the transfer pricing aspects of controlled transactions after the event. This includes analysing contractual terms between related parties as...
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Paul Sutton (LCN Legal) and Philip de Homont (Nera Economic Consulting) set out a framework when considering the allocation of risks in transfer pricing.
In transfer pricing as in everyday life the existence and extent of contractual rights have a significant impact on the financial terms on which parties are willing to enter into transactions. A number of recent decisions in transfer pricing cases have reaffirmed the need for transfer pricing policies to be legally implemented through appropriate intercompany agreements in addition to their implementation in operational practice.
The OECD’s transfer pricing guidelines provide a framework for analysing the transfer pricing aspects of controlled transactions after the event. This includes analysing contractual terms between related parties as...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
