3. Addressing Challenging Transfer Pricing Items which Arose from BEPS - Enrique Rayon

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Agenda • Introduction • Transfer Pricing Documentation • Value Chain Analysis • Profit Split • A note on Comparability post-Brexit or U.S. Tariffs Transfer Pricing | 2017
Introduction • “The BEPS project put meat on the bones of the arm’s length principle.” Pascal Saint-Amans, Director, OECD Centre for Tax Policy and Administration (Bloomberg BNA, Transfer Pricing Report, October 15, 2015) • “BEPS project’s primary objective is to ensure that profits are reported for tax purposes where economic activities are carried out and where value is created.” Raffaele Russo, Head of the OECD/G20 BEPS project group Transfer Pricing | 2017
Page 1: Thinking about your business is a b
Page 5 and 6: Transfer Pricing Documentation •
Page 7 and 8: Value Chain Analysis Conventional S
Page 9 and 10: Profit Split • Transactional prof
Page 11 and 12: Profit Split π Typical Allocation
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3. Addressing Challenging Transfer Pricing Items which Arose from BEPS - Enrique Rayon

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