Shiv Mahalingham, a managing director in Duff & Phelps European Transfer Pricing practice, provides practical and commercial advice in Chief Executive Officer's December 2016 issue. Recent OECD guidance and front-line audit experience has confirmed the importance of designing a transfer pricing policy that ticks as many boxes as possible in as many locations as possible despite the fact that the underlying economic analysis may point to a different result. Considering transfer pricing from the position of both (or all) parties to the transaction is recommended.
Key Points:
- Statutory requirements: inconsistent with the OECD
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Inconsistent local inspector preferences/practice
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Local country margins
- Recommendations from the experts
