Transfer Pricing Analysis definition

Transfer Pricing Analysis means the analysis performed by a transfer pricing specialist determining a remuneration for the Issuer acting in accordance with the purpose of the Notes as described in Clause 2.1. (no economic benefit in relation to the legal ownership of the assets and liabilities).
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Examples of Transfer Pricing Analysis in a sentence

  • The Issuer's corporate income tax return will be filed in accordance with the Transfer Pricing Analysis.

  • My Starbucks’ State Aid Transfer Pricing Analysis: Part II [Blog post].

  • Transfer Pricing Analysis The primary impetus for the Arm’s-Length Adjustment Service has been the identified need of states to find a cost-effective means of evaluating taxpayer transfer pricing studies.

  • The Issuer's financial accounts will show as a result of the Issuer the Net Fee for the relevant financial year as determined in the Transfer Pricing Analysis.

  • The result of the Issuer will always be determined in accordance with the Transfer Pricing Analysis.

  • The AAR held that once the Transfer Pricing Analysis was undertaken, there was no further requirement to attribute profits to a permanent establishment.

  • See Jamal Hejazi & Eric Koh, IFRS: Transitional Impact on Transfer Pricing Analysis, MONDAQ (Jul.

  • Literature - A.M. Rotkowski, Intangible Property in Transfer Pricing Analysis, Intangible transfer Price Insight, Winter 2015, available at: http://www.willamette.com/insights_journal/15/winter_2015_7.pdf.

  • This clearly leads to the inference that the assessee was in a position to dictate the terms and in the absence of any Transfer Pricing Analysis by the Transfer Pricing Officer in the instant case, it cannot be said that such commission could fit the description of “reasonable profits” within the meaning of Article 7 (2) of DTAA.

  • Revised Section E on Safe Harbours in Chapter IV of the Transfer Pricing Guideline”, Annex; Cardoso & Petruzzi, “Simplifying the Transfer Pricing Analysis: An Illusory Chimaera or a Realistic Ambition?”, 12, mentioned that for the remuneration, the range of margin could be determined by undertaking the benchmarking considering the geographical circumstances or industrial types to make the simplification more widely accepted.

Related to Transfer Pricing Analysis

  • Test Report means a written report issued by The Sequoia Project that documents the outcomes of the Testing Process; that is, the Applicant’s compliance with the Specifications and Test Materials.