Transfer pricing: re-evaluating profit splits

Robert Verzi, partner and Philip Brudney, international tax manager at Aprio, outline the implications of the profit split method in transfer pricing as part of the OECD’s Base Erosion and Profit Shifting (BEPS) project and highlight issues for multinationals as they examine global transfer pricing policies 

As part of its BEPS initiative, the OECD identified as one priority "Aligning Transfer Pricing Outcomes with Value Creation" via Actions 8–10. Through a series of discussion drafts, the OECD has promulgated its view of the way forward for transfer pricing for multinationals in the global economy. One of the key drafts addresses the use of the profit split method in transfer pricing, and presents several key issues for multinational companies as they examine their global transfer pricing policies.

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