Abstract The new OECD Transfer Pricing Guidelines concisely present the new tightened documentation requirements1. To align transfer pricing outcomes, i.e., the allocation of taxable income across the group companies, with the value creation (across the integrated value chain) is the revision’s overall objective2. Generally, the transfer pricing documentation consists of Master file and local file….
Tag: TP-Documentation
Transfer Pricing Documentation – more than a matter of duty
The benefit: open up additional profit potential. An integrated group’s transfer pricing policy affects entrepreneurial decisions, performance measurement of both, management and affiliates, as well as the allocation of resources. Creating a documentation, therefore, generates insights useful to make the group more successful. Two cases demonstrate how groups can open up additional profit potential as…