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Applying the Lesson to More Complex Transactions

In: Transfer Pricing in One Lesson

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  • Oliver Treidler

Abstract

Having mastered the application of the arm’s length principle to a range of comparatively simple transactions, this chapter will provide some more advanced guidance on coping with transfer pricing challenges related to management fees (centralized services) as well as financial transactions. The advantages of applying a systematic (sequential) approach that is built on the recommendations of the OECD in the context of the simplified benefit test for management services are illustrated. The reader is provided with a decision tree to guide him through setting up his own allocation mechanism. For financial transactions (loans and cash pooling), the reader is provided with a pragmatic summary of the latest developments in the context of the OECD BEPS project. Concise case studies illustrate the process of choosing an appropriate transfer pricing method as well as conducting exemplary comparability analyses.

Suggested Citation

  • Oliver Treidler, 2020. "Applying the Lesson to More Complex Transactions," Management for Professionals, in: Transfer Pricing in One Lesson, chapter 0, pages 91-116, Springer.
    • Handle: RePEc:spr:mgmchp:978-3-030-25085-0_4
    DOI: 10.1007/978-3-030-25085-0_4
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