The Resource Evaluating whether a distribution affiliate pays arm's-length prices for mining products

Evaluating whether a distribution affiliate pays arm's-length prices for mining products

Label
Evaluating whether a distribution affiliate pays arm's-length prices for mining products
Title
Evaluating whether a distribution affiliate pays arm's-length prices for mining products
Creator
Subject
Language
eng
Summary
This article considers the three basic approaches for evaluating whether a mining affiliate is being paid an arm's length price for the mined goods that it sells to its foreign distribution affiliate. The author concludes that in many situations, an application of the comparable uncontrolled price (CUP) approach will be the best method, but even then an analysis of the distribution affiliate's gross margin may be a necessary component of the analysis. Also discussed are the issues involved when multinationals enter into off-take agreements with their oil and mining affiliates
Citation source
In: Journal of international taxation. - New York. - Vol. 25 (2014),
http://library.link/vocab/creatorName
McClure, J.H
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • arm's length principle
  • mining industry
  • natural resources
  • affiliated company
  • CUP method
  • case law
Label
Evaluating whether a distribution affiliate pays arm's-length prices for mining products
Instantiates
Publication
Label
Evaluating whether a distribution affiliate pays arm's-length prices for mining products
Publication

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