Introduction The Transfer Pricing (TP) rules were introduced to regulate the transactions executed between related companies. The effective TP framework is of main interest in cases where the related parties …
The rules on transfer pricing were introduced in Russia in 2000, were substantially amended in 2011 and came into force on January 1, 2012. The rules did not refer directly …
Sustainable development of EU’ economies requires taking into account several issues, which are related to the increased scale of international trade. Globalization has led to a substantial increase of cross-border …
The transfer pricing of intangible properties has always been a significant issue for multinational enterprises (MNEs). The excellent idea devoted to this matter with the current drive of the OECD …
When states attain membership of the European Union (EU), the governments are in charge of enacting and implementing their local direct taxation policy. The tax framework of the member-states shall …
The implementation of integrated business models and the development of national and multinational groups has been a trend for over 30 years. Many MNEs (Multinational Enterprises) reach a high level …
The arm’s length principle treats the members of a multinational group as operating in separate entities, rather than as inseparable parts of a single unified business. Therefore, it is required …
Transfer Pricing (TP) guidelines generally require associated entities to invoice each other appropriately so as to correspond to the value of the goods transferred or services provided whenever an intra-group …
Introduction This Chapter provides a background discussion of the arm’s length principle, which is the international transfer pricing standard that OECD member countries have agreed should be used for tax …
The selection of a transfer pricing method always aims at finding the most appropriate method for a particular case. For this purpose, the selection process should take account of the …
