International Transfer Pricing

Profit split method

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.

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CODIFYING THE ECONOMIC SUBSTANCE DOCTRINE: Giving an Agency an Enormous Power that Corrupts.

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.

Continue ReadingCODIFYING THE ECONOMIC SUBSTANCE DOCTRINE: Giving an Agency an Enormous Power that Corrupts.