Transfer Pricing: Strategic, Regulatory, and Economic Considerations
Transfer pricing governs how related entities within a multinational corporation price transactions—impacting tax liabilities, operational efficiency, and strategic alignment. Rooted in the arm’s length principle, methods like CUP, Cost Plus, and TNMM ensure fairness and regulatory compliance. The OECD’s BEPS framework mandates robust documentation (Master File, Local File, CbC Report), while strategic considerations include supply chain optimization and performance evaluation. Challenges arise in valuing intangibles, pricing intra-group services, and adapting to digital business models.… Read more