The Profit Split Method is arguably the method likely to give most complete answer as to arm’s length pricing provided the activities performed by the taxpayer and its associated enterprises are inextricably linked and both entities contribute to the value chain. Unlike other methods, it is less susceptible to leave one party with an outcome that may be non-arm's length.
Tax avoidance, by its definition, is an oxymoron. Often times, there is an indicia of illegal overtone, albeit, legal. Tax avoidance is the reduction of tax liability by legal means. It often has pejorative overtones, where for example it is used to describe avoidance achieved by artificial arrangements of personal or business affairs to take advantage of loopholes, anomalies or other deficiencies of tax law.
A transfer pricing professional provides significant value for clients in three distinct ways: 1) ensure compliance with transfer pricing guidelines, 2) provide guidance in planning and optimizing transfer pricing…
OECD Provides Guidance on Transfer Pricing Documentation A transfer price is the price for goods, services or intangibles that are sold or transferred between related legal entities within a multinational…