Transfer pricing

Transfer Pricing - Case studies

 

Consultation with Business on the OECD Discussion Draft on the Attribution of Profits to Permanent Establishments (Parts I & II): Case Study C

16-Apr-2002

Functional analysis, recognition of dealings, characterisation of dealings, attribution of capital to a Banking Permanent Establishment, split functions.

Consultation with Business on the OECD Discussion Draft on the Attribution of Profits to Permanent Establishments (Parts I & II): Case Study A

16-Apr-2002

Relating to the general situation ( Part 1): A permanent establishment is engaged in Research and Development activities leading to the development of intangible property rights. How should dealings be recognised and characterized?

 

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