Transfer Pricing is the set of rules and methodologies applied to transactions between related entities within multinational enterprises (MNEs) ensuring that these intra-group transactions follow the arm’s length principle. In practice, one of the most challenging aspects of Transfer Pricing is the comparability of license agreements, which often involve intangible assets and can be highly complex. Read more: https://lnkd.in/eCmZ7-7j #RoyaltyRange #TransferPricing
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Discover why well-crafted transfer pricing agreements are more than just compliance obligations – they're strategic assets. Partner, Ben Miller, has outlined 10 Key Elements to Consider in a Transfer Pricing Agreement. Learn more here. #BennettThrasher
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Corporate lawyer and leading expert in the legal implementation of transfer pricing policies for multinational groups. Author of 'Intercompany Agreements for Transfer Pricing Compliance - A Practical Guide'.
Form and Substance in Transfer Pricing: Two Sides of the Same Coin. I really enjoyed attending TP Minds International this week, catching up with friends and meeting new ones. But one thing became apparent from some of the conversations and panel discussions: a confusion about the relationship between form and content in transfer pricing. The fundamental building block of transfer pricing is still transactional comparability. The first step of any TP analysis is therefore to identify the controlled transaction. In the context of any transaction, form and substance are two sides of the same coin. You can’t assess substance without having regard to form. Equally, the purported form of a transaction is meaningless without substance. The purpose of intercompany agreements – from a transfer pricing perspective – is to encapsulate both the form and the substance of a transaction. Relying on your ability to make it up after the event is not a great strategy. #TransferPricing #LegalSubstance #IntercompanyAgreements
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Form and substance in transfer pricing: two sides of the same coin... #internationaltax #transferpricing #LCNLegal
Corporate lawyer and leading expert in the legal implementation of transfer pricing policies for multinational groups. Author of 'Intercompany Agreements for Transfer Pricing Compliance - A Practical Guide'.
Form and Substance in Transfer Pricing: Two Sides of the Same Coin. I really enjoyed attending TP Minds International this week, catching up with friends and meeting new ones. But one thing became apparent from some of the conversations and panel discussions: a confusion about the relationship between form and content in transfer pricing. The fundamental building block of transfer pricing is still transactional comparability. The first step of any TP analysis is therefore to identify the controlled transaction. In the context of any transaction, form and substance are two sides of the same coin. You can’t assess substance without having regard to form. Equally, the purported form of a transaction is meaningless without substance. The purpose of intercompany agreements – from a transfer pricing perspective – is to encapsulate both the form and the substance of a transaction. Relying on your ability to make it up after the event is not a great strategy. #TransferPricing #LegalSubstance #IntercompanyAgreements
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Discover why well-crafted transfer pricing agreements are more than just compliance obligations – they're strategic assets. Partner, Ben Miller, has outlined 10 Key Elements to Consider in a Transfer Pricing Agreement. Learn more here. #BennettThrasher
Exploring Key Elements of Transfer Pricing Agreements
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Discover why well-crafted transfer pricing agreements are more than just compliance obligations – they're strategic assets. Partner, Ben Miller, has outlined 10 Key Elements to Consider in a Transfer Pricing Agreement. Learn more here. #BennettThrasher
Exploring Key Elements of Transfer Pricing Agreements
my.socialtoaster.com
-
Discover why well-crafted transfer pricing agreements are more than just compliance obligations – they're strategic assets. Partner, Ben Miller, has outlined 10 Key Elements to Consider in a Transfer Pricing Agreement. Learn more here. #BennettThrasher
Exploring Key Elements of Transfer Pricing Agreements
my.socialtoaster.com
-
Discover why well-crafted transfer pricing agreements are more than just compliance obligations – they're strategic assets. Partner, Ben Miller, has outlined 10 Key Elements to Consider in a Transfer Pricing Agreement. Learn more here. #BennettThrasher
Exploring Key Elements of Transfer Pricing Agreements
my.socialtoaster.com
-
Discover why well-crafted transfer pricing agreements are more than just compliance obligations – they're strategic assets. Partner, Ben Miller, has outlined 10 Key Elements to Consider in a Transfer Pricing Agreement. Learn more here. #BennettThrasher
Exploring Key Elements of Transfer Pricing Agreements
my.socialtoaster.com
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In the area of international business, where transactions occur between related entities across different jurisdictions, ensuring that prices are set at arm's length is extremely important. Transfer Pricing, the practice of determining the prices charged in these transactions, plays the main role in maintaining fairness and transparency within multinational corporations. Read more: https://lnkd.in/emTMnM2X #RoyaltyRange #TransferPricing #CUP #TNMM
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