The 3-tiered approach of the OECD Transfer Pricing Guidelines consists of a Country-by-Country report, a Master File and a Local File. All documents need to be aligned in order to avoid inconsistencies. Setting up these documents in the right way can save time and effort in the long run.
When companies develop their business or evolve into new business models, new transfer pricing structures may need to be considered. Understanding the options available may provide the necessary insight to aligning value creation with profit allocation in an efficient way.
The know-how of tax authorities on transfer pricing has significantly increased over the past years. Questions have become more sophisticated and discussions more complex. Getting the right advise may save a lot of time and effort.
When transferring intellectuals property, exit tax may be applicable. Depending on the facts and circumstances various approaches may be available to determine an arm's length price. Understanding the options available enables management to make a well informed decision.