Structuring Transfer Pricing System. Definition of Transaction Types. Transfer Pricing Methods for Price Setting and Arm’s Length Tests. Fact Pattern Documentation. Arm’s Length Models and Benchmarking.

  • Alignment between budgets, prices setting, monitoring, profit allocation
  • Economics-based transfer pricing within the group
  • Arm’s length principle and demonstration of “serious effort”
  • Active tax risk management

With the GTP® MANAGER and its toolkit model, the related-party transactions can be systematically structuring with ease – half way to the transfer pricing documentation.

 

Elements:
  • Business relationships
  • Transaction types
  • Price setting models
  • Monitoring and controlling measures
  • Arm’s length test models
  • Arm’s length information
  • Contract templates
  • Documentation concepts