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Know the blind spots and complexities to get your TP right in this area

The myth that using the “cost plus 5% mark-up” practice for any intra-group service transaction makes an organisation compliant with transfer pricing regulations runs deep and is widely followed, but is ultimately erroneous.

Get attuned on the finer details to stand up to scrutiny by tax authorities

A subsidiary borrows from a third party at 1% to 2% and on-lends to its head office at a significantly higher interest rate. This arrangement resulted in its head office claiming a large interest deduction and the subsidiary earning a profit of over $1 billion which was not taxed in any country. Sounds familiar?

In recent years, Transfer Pricing has seized a lot of our attention, especially in Asian countries.

The tax authorities are catching up on the implementation of BEPS Action Plans, often adding compliance burdens to the business leaders. With two or more jurisdictions involved, the challenge is how we can satisfy all of their requirements.

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