The Profit Split Method (PSM) is gaining prominence in transfer pricing to ensure fair profit allocation among multinational enterprises. Learn when to apply the PSM based on unique and valuable contributions, highly integrated operations, or shared economically significant risks between controlled parties. Discover how the PSM aligns with the OECD’s BEPS initiative by considering the relative value contributed by each party to the transaction. Explore the origins, strengths, and practical applications of PSM. This article provides insights on using the PSM for arm’s-length pricing, tax planning, and defending against transfer pricing examinations. Continue reading
Tag Archives: Transfer Pricing Methods
IRS Transfer Pricing Audit Roadmap
Transfer Pricing NEWS The Transfer Pricing Operations (TPO) of the Large Business and International (LB&I) division of IRS released the 26-page Transfer Pricing Audit Roadmap to the public on February 14, 2014. The Transfer Pricing Audit Roadmap (“Roadmap”) provides audit procedures around an approximate 24-month audit timeline. The stated goals of the roadmap are to assist both … Continue reading
New Ukraine Transfer Pricing Rules
Prior to 2012, Ukraine had not been overly concerned about transfer pricing issues. But recently, in the era of fiscal deficits, the Ukrainian government has been more focused on implementing transfer pricing compliance practices in accordance with OECD member countries. Transfer Pricing NEWS On December 4, 2012 the Parliament of Ukraine registered the draft bill … Continue reading
Did it take almost 2.5 years for the CRA to read the 2010 version of the OECD TP Guidelines?
Did it take almost 2.5 years for the CRA to read the 2010 version of the OECD TP Guidelines? Apparently. CRA released Transfer Pricing Memorandum 14 on October 31, 2012, basically saying they agree with the OECD. Continue reading