TP documentation through global value chain analysis

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.