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Low Value Adding Services in Transfer Pricing

The concept of low value added services (LVATS) represents one of the most significant developments in international transfer pricing since the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) initiative 1. This simplified approach addresses the long-standing challenges multinational enterprises (MNEs) face when pricing routine, administrative services between related entities across different tax jurisdictions 2. The framework emerged from the recognition that traditional transfer pricing methods often impose disproportionate compliance burdens on relatively straightforward intra-group service transactions that add limited economic value 3.

Historical Development and the BEPS Initiative

The LVATS framework originated from the OECD’s comprehensive review of international tax rules under the BEPS Action Plan, specifically Action 10, which focused on aligning transfer pricing outcomes with value creation 4. Prior to this development, multinational groups struggled with the complexity and cost of applying full transfer pricing documentation and analysis to routine services such as payroll processing, basic information technology support, and administrative functions 5.

The BEPS project, launched in 2013 and completed in 2015, identified transfer pricing as a key area requiring reform to prevent artificial profit shifting and ensure that profits are taxed where economic activities occur and value is created 6. Action 10 specifically addressed transfer pricing aspects of other high-risk transactions, including low value-adding intra-group services 7.

The traditional approach required detailed functional analysis, extensive benchmarking studies, and comprehensive documentation for even the most routine services 8. This created a significant administrative burden that was often disproportionate to the economic significance of the transactions and the tax revenue at stake 9. Tax administrations also faced challenges in auditing these transactions efficiently, leading to disputes and double taxation issues 10.

Defining Low Value Added Services

Low value added services are characterized by their supportive nature and limited contribution to the key value drivers of the MNE group 11. The OECD Guidelines define these services as activities that are supportive in nature, do not constitute part of the core business of the MNE group, do not require the use of unique and valuable intangibles, and do not involve the assumption or control of substantial or significant risks by the service provider 12.

The key characteristics distinguishing LVATS from other intra-group services include their routine and standardized nature, limited decision-making requirements, absence of unique value creation, and minimal risk assumption 13. These services typically support the main business activities of group entities rather than driving profit generation directly 14.

Categories of Low Value Added Services

The OECD Guidelines and related guidance identify several broad categories of services that commonly qualify as low value added 15. Information technology services encompass routine system maintenance, helpdesk support, data processing, and basic software management that do not involve proprietary technology or strategic decision-making 16.

Human resources services include payroll processing, benefits administration, recruitment coordination, basic training programs, and personnel record management 17. These activities support the workforce but do not create unique value or require specialized expertise beyond standard HR practices 18.

Legal and compliance services that qualify as LVATS typically involve routine contract review, standard legal documentation, regulatory compliance monitoring, and basic corporate secretarial functions 19. Strategic legal advice, complex litigation management, or specialized intellectual property work would generally not qualify due to their higher value-adding nature 20.

Accounting and administrative services represent a significant category, including basic bookkeeping, accounts payable and receivable processing, routine financial reporting, and standard tax compliance activities 21. These services maintain operational efficiency but do not involve strategic financial planning or complex analysis 22.

The Simplified Approach Framework

The LVATS simplified approach provides an elective safe harbor mechanism that allows qualifying services to be priced using a standardized cost-plus method with a predetermined markup range 23. This represents a significant departure from the traditional requirement for detailed benchmarking studies and extensive comparability analysis 24.

Under the simplified approach, eligible services can be charged at cost plus a markup of typically 2-5 percent, though the specific rate may vary by jurisdiction 25. The markup is applied to the direct and indirect costs of providing the services, calculated using consistent accounting principles 26.

The approach requires that costs be determined using the same accounting principles consistently applied across the MNE group for financial reporting purposes 27. This ensures transparency and reduces the potential for manipulation while maintaining simplicity 28. The service provider must maintain adequate documentation to support the cost calculations and demonstrate that the services qualify for the simplified approach 29.

Cost Pool Methodology

The simplified approach utilizes a cost pooling methodology that aggregates eligible LVATS costs and allocates them among beneficiary entities based on reasonable allocation keys 30. This pooled approach recognizes the practical reality that many administrative services benefit multiple group entities simultaneously and that separate tracking for each beneficiary would be disproportionately burdensome 31.

Allocation keys must reflect the relative benefits received by each entity and may include metrics such as headcount, revenues, costs, assets, or other measures that correlate with service consumption 32. The selection of appropriate allocation keys requires careful consideration of the nature of the services and the business operations of the beneficiary entities 33.

Eligibility Criteria and Requirements

The LVATS simplified approach includes specific eligibility criteria designed to ensure that only genuinely low value-adding services benefit from the simplified treatment 34. These criteria serve as safeguards against potential abuse while maintaining the administrative benefits of the approach 35.

The benefit test requires that the service provides economic or commercial value to the recipient entity 36. This fundamental requirement ensures that charges are only made for services that an independent enterprise would be willing to pay for or perform itself 37.

Services must be supportive in nature rather than core business activities 38. This distinction prevents high-value strategic activities from being inappropriately characterized as LVATS 39. The service provider should not control significant risks related to the services or use unique and valuable intangibles in their provision 40.

Exclusions and Limitations

Certain categories of services are explicitly excluded from LVATS treatment due to their inherently higher value-adding nature 41. Research and development activities, regardless of their routine appearance, typically involve significant value creation and risk assumption 42.

Manufacturing, production, and assembly services are generally excluded as they involve substantial operational risks and contribute directly to value creation 43. Similarly, distribution, sales, and marketing services that involve market-facing activities and revenue generation typically do not qualify 44.

Financial services, including lending, borrowing, hedging, and treasury management beyond basic administrative functions, are excluded due to their strategic importance and risk characteristics 45. Management and control activities that involve significant decision-making authority also fall outside the LVATS framework 46.

Practical Application and Implementation

The practical implementation of LVATS requires careful planning and documentation to ensure compliance with both the simplified approach requirements and general transfer pricing principles 47. Organizations must establish appropriate governance structures to identify qualifying services, maintain cost records, and monitor ongoing compliance 48.

Service agreements should clearly define the scope of LVATS activities and distinguish them from higher value-adding services 49. This documentation helps support the qualification assessment and provides clarity for both tax compliance and business operations 50. Regular reviews of service classifications ensure continued appropriateness as business activities evolve 51.

Cost accounting systems must be capable of accurately tracking LVATS costs and supporting the allocation methodology 52. This may require system modifications or enhanced procedures to ensure proper cost capture and allocation 53.

Documentation Requirements

While the simplified approach reduces documentation burdens compared to traditional methods, certain documentation requirements remain essential 54. Service providers must maintain records demonstrating that services qualify for LVATS treatment and supporting the cost calculations 55.

Documentation should include service descriptions, cost calculations, allocation key methodologies, and evidence of benefits provided to recipients 56. This documentation serves both compliance and audit defense purposes 57.

Regular monitoring and review processes help ensure continued compliance and identify any changes in service characteristics that might affect LVATS eligibility 58. This ongoing assessment is particularly important as business operations evolve and new services are added 59.

Benefits and Limitations of the Simplified Approach

The LVATS framework offers significant benefits for both taxpayers and tax administrations 60. For multinational enterprises, the primary advantage is the substantial reduction in compliance costs and administrative burden 61. The simplified approach eliminates the need for extensive benchmarking studies and detailed comparability analysis for qualifying services 62.

The standardized markup approach provides greater certainty and predictability for transfer pricing outcomes 63. This reduces the risk of disputes and double taxation while enabling more efficient resource allocation for transfer pricing compliance 64. The elective nature of the approach allows taxpayers to opt out if traditional methods would produce more favorable results 65.

Tax administrations benefit from reduced audit complexity and more efficient resource utilization 66. The standardized approach enables auditors to focus on higher-risk transactions while maintaining appropriate oversight of routine services 67. The simplified documentation requirements also facilitate more streamlined audit processes 68.

Limitations and Considerations

Despite its benefits, the LVATS approach has certain limitations that organizations must consider 69. The predetermined markup may not always reflect the specific circumstances of particular services or markets 70. In some cases, traditional transfer pricing methods might support a different, potentially more favorable, pricing outcome 71.

The eligibility criteria may exclude services that appear routine but involve subtle value-adding characteristics 72. Careful analysis is required to ensure proper classification, and the consequences of misclassification can include penalties and adjustments 73.

The approach requires consistent application across all relevant jurisdictions, which may be challenging in practice due to different local implementations or interpretations 74. Some jurisdictions may not have adopted the LVATS framework or may have implemented variations that create coordination difficulties 75.

Comparative Analysis with Traditional Transfer Pricing Methods

The LVATS simplified approach represents a significant departure from traditional transfer pricing methodologies 76. Traditional approaches typically require extensive functional analysis, identification of tested parties, selection of appropriate transfer pricing methods, and detailed benchmarking studies 77.

The comparable uncontrolled price (CUP) method, while theoretically most accurate, is often impractical for routine services due to the lack of sufficiently comparable third-party transactions 78. The cost-plus method, commonly used for service transactions, requires detailed benchmarking to establish appropriate markup ranges 79.

The transactional net margin method (TNMM) involves complex profit level indicator analysis and extensive database searching to identify comparable companies 80. These traditional approaches, while comprehensive, often result in compliance costs that exceed the economic significance of routine service transactions 81.

Economic Efficiency Considerations

From an economic efficiency perspective, the LVATS approach recognizes that the costs of compliance should be proportionate to the economic significance of transactions 82. Traditional methods may be over-engineered for routine services, creating deadweight losses that reduce overall economic welfare 83.

The simplified approach promotes better resource allocation by allowing organizations to focus detailed transfer pricing analysis on transactions that truly drive value creation 84. This aligns with the BEPS objective of ensuring that transfer pricing outcomes reflect economic substance rather than purely technical compliance 85.

However, the standardized nature of the approach may not capture all relevant economic factors that could affect arm’s length pricing 86. This trade-off between simplicity and precision requires careful consideration in each implementation 87.

Global Implementation and Jurisdictional Variations

The adoption of LVATS provisions varies significantly across jurisdictions, reflecting different policy priorities and administrative capabilities 88. Many OECD member countries have implemented versions of the simplified approach, though with varying details and requirements 89.

Some jurisdictions have adopted the OECD framework with minimal modifications, while others have introduced additional requirements or limitations 90. These variations can create challenges for multinational enterprises operating across multiple jurisdictions 91. Common variations include different markup rates, alternative eligibility criteria, and varying documentation requirements 92.

Developing countries face particular challenges in implementing LVATS provisions due to limited administrative resources and concerns about potential revenue loss 93. Some jurisdictions worry that simplified approaches may be used inappropriately to reduce tax liabilities on higher value-adding activities 94.

Coordination and Mutual Agreement Procedures

The success of LVATS implementation depends significantly on international coordination and the availability of dispute resolution mechanisms 95. Mutual agreement procedures (MAP) play a crucial role in resolving conflicts that arise from different jurisdictional interpretations or implementations 96.

The OECD continues to work on guidance and best practices to promote consistent implementation across jurisdictions 97. This includes model legislation, implementation guidance, and training programs for tax administrators 98.

Advance pricing agreements (APAs) can provide additional certainty for LVATS arrangements, particularly in complex multinational structures 99. These agreements help prevent disputes and provide long-term pricing certainty 100.

Industry-Specific Considerations and Applications

Different industries face varying challenges and opportunities in implementing LVATS approaches 101. Technology companies often have extensive shared service operations that include both qualifying LVATS activities and higher value-adding functions requiring careful segregation 102.

Financial services organizations must navigate complex regulatory requirements while identifying routine administrative functions that qualify for simplified treatment 103. Manufacturing companies typically have centralized procurement, quality control, and technical support functions that may qualify as LVATS 104.

Pharmaceutical and life sciences companies face particular challenges due to the specialized nature of many support services and the prevalence of intellectual property considerations 105. Even routine-appearing activities may involve valuable intangibles or specialized knowledge that affects LVATS eligibility 106.

Service Industry Applications

Pure service industries, including consulting, professional services, and business process outsourcing, present unique LVATS considerations 107. These organizations may provide LVATS to their own group entities while delivering higher value-adding services to external clients 108.

The distinction between routine administrative support and core business activities becomes particularly important in service industries 109. Careful functional analysis is required to ensure appropriate classification and avoid inappropriate use of simplified approaches 110.

Risk Management and Compliance Strategies

Effective LVATS implementation requires comprehensive risk management and compliance strategies 111. Organizations must establish governance frameworks that ensure proper identification, documentation, and monitoring of qualifying services 112.

Risk assessment should consider both tax compliance risks and business operational risks 113. Misclassification of services can result in transfer pricing adjustments, penalties, and reputational damage 114. Regular compliance reviews and updates to service classifications help mitigate these risks 115.

Training and awareness programs ensure that personnel understand LVATS requirements and can identify changes in service characteristics that might affect eligibility 116. This is particularly important as business operations evolve and new services are introduced 117.

Audit Preparation and Defense

While LVATS approaches reduce audit complexity, proper preparation remains essential 118. Documentation should be organized and readily accessible to support audit defense 119. This includes service descriptions, cost calculations, allocation methodologies, and evidence of benefits provided 120.

Regular self-assessment and internal reviews help identify potential issues before they become audit concerns 121. Engaging with tax advisors and maintaining current knowledge of regulatory developments supports effective audit preparation 122.

Future Developments and Emerging Trends

The LVATS framework continues to evolve as jurisdictions gain experience with implementation and the business environment changes 123. Digitalization and automation are changing the nature of many administrative services, potentially affecting LVATS classifications 124.

The rise of shared service centers and global business services organizations creates new opportunities and challenges for LVATS implementation 125. These centralized operations often provide a mix of routine and specialized services requiring careful analysis 126.

Regulatory developments, including updates to the OECD Guidelines and new jurisdictional implementations, continue to shape the LVATS landscape 127. Organizations must maintain awareness of these developments to ensure continued compliance 128.

The increasing focus on environmental, social, and governance (ESG) considerations may also affect how services are categorized and valued in the future 129. Sustainability and social responsibility initiatives may add value dimensions that affect LVATS eligibility 130.

The low value added services framework represents a significant advancement in transfer pricing practice, providing a pragmatic solution to long-standing compliance challenges while maintaining the integrity of the arm’s length principle 131. Successful implementation requires careful planning, appropriate governance, and ongoing monitoring to ensure continued compliance and effectiveness 132. As the framework continues to evolve, organizations must balance the benefits of simplification with the need for accurate reflection of economic substance in their transfer pricing arrangements 133.

  1. OECD, Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 – 2015 Final Reports, OECD/G20 Base Erosion and Profit Shifting Project, 2015, OECD Publishing, Paris
  2. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.1
  3. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 2
  4. OECD, Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 – 2015 Final Reports, OECD/G20 Base Erosion and Profit Shifting Project, 2015, OECD Publishing, Paris, page 3
  5. Ioana Ignat and Liliana Ionescu-Feleaga, Transfer Pricing in Manufacturing: An Analysis of the OECD Guidelines, 2022, Springer Nature Switzerland AG, page 21
  6. OECD, Action Plan on Base Erosion and Profit Shifting, 2013, OECD Publishing, Paris
  7. OECD, Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 – 2015 Final Reports, OECD/G20 Base Erosion and Profit Shifting Project, 2015, OECD Publishing, Paris, Action 10
  8. Dahlia Sari, Sidharta Utama, Fitriany and Ning Rahayu, Transfer pricing practices and specific anti-avoidance rules in Asian developing countries, International Journal of Accounting, 2020, page 2
  9. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 430
  10. Resolving Transfer Pricing Disputes: A Global Analysis, 2019, IBFD Publications, Chapter 20, page 826
  11. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.42
  12. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.42
  13. Jay Pil Choi, Taiji Furusawa and Jota Ishikawa, Transfer pricing regulation and tax competition, Journal of International Economics, 2020, Elsevier, page 1
  14. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 3
  15. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.43
  16. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Annex 1
  17. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.43
  18. Ioana Ignat and Liliana Ionescu-Feleaga, Transfer Pricing in Manufacturing: An Analysis of the OECD Guidelines, 2022, Springer Nature Switzerland AG, page 34
  19. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.43
  20. Bjorn Heidecke, Intangibles in the World of Transfer Pricing, 2021, Springer Nature Switzerland AG, page 263
  21. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.43
  22. Moritz Hiemann and Stefan Reichelstein, Fundamentals of International Transfer Pricing in Law and Economics, 2021, University of Chicago Press, page 6
  23. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.44
  24. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 4
  25. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.44
  26. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.45
  27. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.46
  28. Jay Pil Choi, Taiji Furusawa and Jota Ishikawa, Transfer pricing regulation and tax competition, Journal of International Economics, 2020, Elsevier, page 5
  29. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.52
  30. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.47
  31. Ioana Ignat and Liliana Ionescu-Feleaga, Transfer Pricing in Manufacturing: An Analysis of the OECD Guidelines, 2022, Springer Nature Switzerland AG, page 37
  32. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.47
  33. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 6
  34. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.48
  35. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 431
  36. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.6
  37. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.6
  38. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.42
  39. Dahlia Sari, Sidharta Utama, Fitriany and Ning Rahayu, Transfer pricing practices and specific anti-avoidance rules in Asian developing countries, International Journal of Accounting, 2020, page 4
  40. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.42
  41. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.48
  42. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.48
  43. Ioana Ignat and Liliana Ionescu-Feleaga, Transfer Pricing in Manufacturing: An Analysis of the OECD Guidelines, 2022, Springer Nature Switzerland AG, page 60
  44. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.48
  45. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.48
  46. Jay Pil Choi, Taiji Furusawa and Jota Ishikawa, Transfer pricing regulation and tax competition, Journal of International Economics, 2020, Elsevier, page 8
  47. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 432
  48. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 8
  49. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.52
  50. Ioana Ignat and Liliana Ionescu-Feleaga, Transfer Pricing in Manufacturing: An Analysis of the OECD Guidelines, 2022, Springer Nature Switzerland AG, page 30
  51. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 433
  52. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.47
  53. Moritz Hiemann and Stefan Reichelstein, Fundamentals of International Transfer Pricing in Law and Economics, 2021, University of Chicago Press, page 8
  54. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.52
  55. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 12
  56. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.52
  57. Resolving Transfer Pricing Disputes: A Global Analysis, 2019, IBFD Publications, Chapter 20, page 827
  58. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.52
  59. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 10
  60. OECD, Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 – 2015 Final Reports, OECD/G20 Base Erosion and Profit Shifting Project, 2015, OECD Publishing, Paris, Action 10
  61. Dahlia Sari, Sidharta Utama, Fitriany and Ning Rahayu, Transfer pricing practices and specific anti-avoidance rules in Asian developing countries, International Journal of Accounting, 2020, page 6
  62. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 12
  63. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.44
  64. Jay Pil Choi, Taiji Furusawa and Jota Ishikawa, Transfer pricing regulation and tax competition, Journal of International Economics, 2020, Elsevier, page 12
  65. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.44
  66. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 434
  67. Resolving Transfer Pricing Disputes: A Global Analysis, 2019, IBFD Publications, Chapter 20, page 828
  68. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 13
  69. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.50
  70. Jay Pil Choi, Taiji Furusawa and Jota Ishikawa, Transfer pricing regulation and tax competition, Journal of International Economics, 2020, Elsevier, page 15
  71. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 14
  72. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.48
  73. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.50
  74. Dahlia Sari, Sidharta Utama, Fitriany and Ning Rahayu, Transfer pricing practices and specific anti-avoidance rules in Asian developing countries, International Journal of Accounting, 2020, page 8
  75. Resolving Transfer Pricing Disputes: A Global Analysis, 2019, IBFD Publications, Chapter 20, page 829
  76. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter II
  77. Ioana Ignat and Liliana Ionescu-Feleaga, Transfer Pricing in Manufacturing: An Analysis of the OECD Guidelines, 2022, Springer Nature Switzerland AG, page 37
  78. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 2.13
  79. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 2.31
  80. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 2.45
  81. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 16
  82. OECD, Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 – 2015 Final Reports, OECD/G20 Base Erosion and Profit Shifting Project, 2015, OECD Publishing, Paris, page 15
  83. Jay Pil Choi, Taiji Furusawa and Jota Ishikawa, Transfer pricing regulation and tax competition, Journal of International Economics, 2020, Elsevier, page 18
  84. OECD, Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 – 2015 Final Reports, OECD/G20 Base Erosion and Profit Shifting Project, 2015, OECD Publishing, Paris, page 16
  85. OECD, Action Plan on Base Erosion and Profit Shifting, 2013, OECD Publishing, Paris, page 3
  86. Moritz Hiemann and Stefan Reichelstein, Fundamentals of International Transfer Pricing in Law and Economics, 2021, University of Chicago Press, page 12
  87. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 18
  88. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 432
  89. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.44
  90. Dahlia Sari, Sidharta Utama, Fitriany and Ning Rahayu, Transfer pricing practices and specific anti-avoidance rules in Asian developing countries, International Journal of Accounting, 2020, page 10
  91. Resolving Transfer Pricing Disputes: A Global Analysis, 2019, IBFD Publications, Chapter 20, page 827
  92. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 433
  93. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 431
  94. Dahlia Sari, Sidharta Utama, Fitriany and Ning Rahayu, Transfer pricing practices and specific anti-avoidance rules in Asian developing countries, International Journal of Accounting, 2020, page 12
  95. Resolving Transfer Pricing Disputes: A Global Analysis, 2019, IBFD Publications, Chapter 20, page 826
  96. Resolving Transfer Pricing Disputes: A Global Analysis, 2019, IBFD Publications, Chapter 20, page 827
  97. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Preface
  98. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 434
  99. Resolving Transfer Pricing Disputes: A Global Analysis, 2019, IBFD Publications, Chapter 20, page 827
  100. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 15
  101. Ioana Ignat and Liliana Ionescu-Feleaga, Transfer Pricing in Manufacturing: An Analysis of the OECD Guidelines, 2022, Springer Nature Switzerland AG, page 86
  102. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 20
  103. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.48
  104. Ioana Ignat and Liliana Ionescu-Feleaga, Transfer Pricing in Manufacturing: An Analysis of the OECD Guidelines, 2022, Springer Nature Switzerland AG, page 99
  105. Bjorn Heidecke, Intangibles in the World of Transfer Pricing, 2021, Springer Nature Switzerland AG, page 265
  106. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 6.155
  107. Dahlia Sari, Sidharta Utama, Fitriany and Ning Rahayu, Transfer pricing practices and specific anti-avoidance rules in Asian developing countries, International Journal of Accounting, 2020, page 14
  108. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 22
  109. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.42
  110. Ioana Ignat and Liliana Ionescu-Feleaga, Transfer Pricing in Manufacturing: An Analysis of the OECD Guidelines, 2022, Springer Nature Switzerland AG, page 34
  111. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 430
  112. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 24
  113. Dahlia Sari, Sidharta Utama, Fitriany and Ning Rahayu, Transfer pricing practices and specific anti-avoidance rules in Asian developing countries, International Journal of Accounting, 2020, page 16
  114. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.50
  115. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 13
  116. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 434
  117. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 26
  118. Resolving Transfer Pricing Disputes: A Global Analysis, 2019, IBFD Publications, Chapter 20, page 828
  119. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.52
  120. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 12
  121. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 13
  122. Resolving Transfer Pricing Disputes: A Global Analysis, 2019, IBFD Publications, Chapter 20, page 829
  123. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Preface
  124. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 28
  125. Dahlia Sari, Sidharta Utama, Fitriany and Ning Rahayu, Transfer pricing practices and specific anti-avoidance rules in Asian developing countries, International Journal of Accounting, 2020, page 18
  126. Ioana Ignat and Liliana Ionescu-Feleaga, Transfer Pricing in Manufacturing: An Analysis of the OECD Guidelines, 2022, Springer Nature Switzerland AG, page 101
  127. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Preface
  128. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 434
  129. Jay Pil Choi, Taiji Furusawa and Jota Ishikawa, Transfer pricing regulation and tax competition, Journal of International Economics, 2020, Elsevier, page 25
  130. Christian Plesner Rossing, Martine Cools and Carsten Rohde, International transfer pricing in multinational enterprises, Management Accounting Research, 2017, Elsevier Ltd., page 30
  131. OECD, Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 – 2015 Final Reports, OECD/G20 Base Erosion and Profit Shifting Project, 2015, OECD Publishing, Paris, Action 10
  132. UN Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter 11, page 434
  133. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Section 7.52
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