Conducting a Transfer Pricing Trial
by Dr Daniel N Erasmus
Dr Daniel N Erasmus focuses on tax controversy with a general emphasis on complex domestic and international issues and a particular emphasis on transfer pricing issues. His transfer pricing experience includes extensive involvement with the identification, valuation, and movement of intangible property in a variety …
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by Dr Daniel N Erasmus
Having prepared and argued at numerous Transfer Pricing trials, I thought it a good idea to commit my journey and experiences to paper as a guide to others about to travel this path in a tumultuous world where revenue authorities are looking to maximize their tax collections.
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Read MoreIn the case of a specific brand, ABC, the supplier makes ABC available to the buyer. Say then, the revenue authority proffers an ALP determination process but valuing the brand using a ‘prime premium’ method. How does this basic fundamental analysis assist? In basic terms, …
Read MoreBy looking at and analyzing the basic starting point of the transfer pricing study, and what it is addressing, in very specific terms, the alignment with the most appropriate OECD and UN TPGs that should apply, become obvious. These guidelines produce specific axioms defined as: …
Read MoreTHE TRANSFER PRICING STUDY STARTING POINT It all starts with the MNE’s transfer pricing study, hopefully prepared annually, that encapsulates the approach of the MNE and all its subsidiaries or Opcos to comply with the legislation, as guided by the OECD and UN Transfer Pricing …
Read MoreLawyers (and especially judges) tend to focus on those areas of law they are comfortable with when analyzing facts and applying the principles of law, developed by the interpretations of words and phrases they are used to seeing. Pitch this alternative approach to the transfer …
Read MoreIntroduction Having prepared and argued at numerous Transfer Pricing trials, I thought it a good idea to commit my journey and experiences to paper. As sort of a guide to others about to travel this path in a tumultuous world where revenue authorities are looking …
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