Comparable Uncontrolled Price (CUP method) in Real World

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 multinational enterprises (MNEs) to follow the same pricing policy for intra-group and uncontrolled transactions, under comparable circumstances. Otherwise, the controlled companies shall take the necessary … Read more

Documenting intragroup transactions on machinery and equipment

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 transaction takes place. The basis for determining proper compensation is, in most cases, the arm’s length principle. In a nutshell, the arm’s-length principle requires that … Read more

IAS 24 for Related Party Transactions

The objective of IAS 24 Standard is to ensure that an entity’s financial statements contain the disclosures necessary to draw attention to the possibility that its financial position and profit or loss may have been affected by the existence of related parties and by transactions and outstanding balances, including commitments, with such parties. Related party … Read more

Transfer Pricing Practices in Russia

Although Russia is a Non-OECD economy there are certain provisions for the implementation of transfer pricing policies in related party transactions. The regulatory framework is not keen on preventing tax avoidance through transfer pricing schemes. However, accountants, auditors and tax professionals are aware for the principles, while Russian tax administration is alerted indeed. Reference to … Read more