ARTICLE · 08 MAY 2023

Value Chain Analysis – The Future Of Transfer Pricing

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As contentious as transfer pricing can be in many respects, there is an established set of principles generally agreed upon under the Transfer Pricing Guidelines for Multinational Enterprises...

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Classical transactional transfer pricing

As contentious as transfer pricing can be in many respects, there is an established set of principles generally agreed upon under the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations issued by the Organisation for Economic Cooperation and Development ("OECD Guidelines") as well as accepted by most regimes.

Most of the debate is around interpreting the facts and the application of suitable methods based on third-party data. Typically, only the prices of individual transactions and the simplest sides of transactions are looked at, while the entrepreneurial entities and the full value chain receive limited focus.

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