Download An Analysis of Adequate OECD Transfer Pricing Methods for by Melanie Keller PDF

By Melanie Keller
In order to figure out the costs and sales for the linked businesses, move costs (TP) need to be set for the respective items of intra-group transfers (Organisation for financial Co-operation and improvement [OECD]). Intra-group transfers might be outlined because the transaction of exact or intangible estate from one entity of a MNE to a different entity, regarded as sale and “may practice to departments, divisions, subsidiaries, or associate company devices” . A TP for this reason is the inner financial price im-posed on items, companies or unmanufactured fabric that's transferred inside of a MNE staff. in line with the OECD (2010) intra-firm transfers are likewise de-fined as managed transactions (i.e., transactions among linked enterprises).
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