Transfer Pricing

The allocation of management fees within a multinational enterprise ("MNE") is considered a form of base erosion, in the OECD Action Plan on Base Erosion and Profit Shifting (“BEPS”). A current survey of consulting group WTS has examined such allocations. The survey shows that many countries already have implemented regulations controlling the tax treatment of management service fees. However, such regulations often vary from country to country. As such, the preparation of a suitable transfer pricing documentation is recommended in order to avoid a possible double taxation for MNEs.

The WTS survey can be downloaded here.

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