In the March edition of the magazine, Johann Muller, a member of the Danish Competent Authority for transfer pricing (TP), wrote about the issues that need to be addressed when looking at examples 1 and 2 to Annex C of the OECD Base Erosion and Profit Shifting (BEPS) report. Now, he proposes a simplified transfer pricing documentation process for vertically integrated multinational enterprises (MNEs). Both articles are written on a personal level and do not reflect the views of the Danish government.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals