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The OECD BEPS initiative has introduced numerous likely challenges to transfer pricing structures defended through application of the transactional net margin method (TNMM). This article focuses on the economic analysis enhancements needed to make TNMM-type transfer pricing solutions sustainable in the future.
In the first of a series on transfer pricing technical challenges and solutions to changing economic and regulatory environments for global multinationals, this article focuses on the remuneration of top management functions in the inter-company context.
