Transfer pricing is a hot topic both for Tax and Treasury. Treasury Mastermind user Paul Buck wrote an interesting blog about it here.
It remains often a matter of interpretation of the OECD rules and the internal application is also not very easy. Especially for smaller IC entities with limited substance or track record.
This forum post is to share use cases, tips and tricks on how to implement transfer pricing and be compliant with the OECD rules.
The most important thing is to ensure proper documentation that clearly and concisely outlines the transfer pricing policies, and rationale for pricing decisions. This documentation should show that the pricing of intercompany transactions is in line with the arm’s length principle as outlined by the OECD guidelines.
.
