The Resource French Supreme Court recognizes the significance of the functional analysis in line with the OECD TPG

French Supreme Court recognizes the significance of the functional analysis in line with the OECD TPG

Label
French Supreme Court recognizes the significance of the functional analysis in line with the OECD TPG
Title
French Supreme Court recognizes the significance of the functional analysis in line with the OECD TPG
Creator
Subject
Language
eng
Summary
The SKF Holding case discusses the importance of the functional analysis which, despite being probably the most subjective and thus challenging part when applying transfer pricing rules, constitutes the core of any transfer pricing analysis. Understanding the activities that parties perform, the assets that they utilize, and the risks that they assume, as well as the relative importance of each in establishing the transfer price (i.e., payment) is a challenging undertaking that provides unique problems for both MNEs and tax authorities
Citation source
In: TPI - Transfer Pricing International. - Wien. - Vol. 6 (2022), no. 1 ; p. 32-36
http://library.link/vocab/creatorName
Screpante, M.S
Geographic coverage
  • Europe
  • European Union
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • functional analysis
  • risk
  • control
  • OECD Transfer Pricing Guidelines
  • case law
Label
French Supreme Court recognizes the significance of the functional analysis in line with the OECD TPG
Instantiates
Publication
Label
French Supreme Court recognizes the significance of the functional analysis in line with the OECD TPG
Publication

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