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Transfer Pricing Aspects of Performance Guarantees ...

Jul 27, 2018 · The fact that performance guarantees typically relate to long-term large contracts makes them a convenient target. In this short blog, we provide an over-view of the Transfer Pricing (TP) approaches to intra-group performance guarantees and discuss them from a practical perspective, mainly based on the OECD 2017 TP Guidelines and the US TP rules.…

Navigating the complexity - PwC

transfer pricing treatment of intercompany financial transactions (e.g. APAs, ATCAs, etc.)? • How does your country deal with the transfer pricing aspects of intercompany loans and guarantees: is an intercompany transaction recognised and is a fee (interest rate, guarantee fee) justified?…

The new transfer pricing landscape A practical guide to ...

The new transfer pricing landscape A practical guide to the BEPS changes Global Transfer Pricing November 2015. ... will the new guidance impact your company? In this book, the transfer pricing professionals of Deloitte have attempted ... of transfer pricing topics, including risk, intangibles, the role of contracts, and funding, and the new ...…

Benchmarking of corporate ... - Transfer Pricing Blog

May 19, 2014 · One of the readers of the blog asked to discuss an appropriate and practical methodology for benchmarking corporate and/or performance guarantees. Further the reader states: “From the material I have been able to read till now, the interest saving approach discussed in the GE Canada judgment is one way to do it. Theoretically, the risk ……