In order for economic analysis in transfer pricing to have substance, it must be considered hand-in-hand with the design of appropriate intercompany agreements to implement the intended arrangements. This article provides a suggested framework for tax professionals when considering the allocation of risks, using examples relating to the application of the ‘transactional profit split method’ in transfer pricing.
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In order for economic analysis in transfer pricing to have substance, it must be considered hand-in-hand with the design of appropriate intercompany agreements to implement the intended arrangements. This article provides a suggested framework for tax professionals when considering the allocation of risks, using examples relating to the application of the ‘transactional profit split method’ in transfer pricing.
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