MONTCLARECAPITAL PARTNERSHow international groups price what they exchange between their own companies, and defend it to more than one tax authority.
The problem in one sentence
The arm's length principle in practice
The functional analysis: profit follows function, asset and risk
The recognised methods
Documentation: the master file and the local files
Timing: contemporaneous, not reconstructed
Financing between group companies
When two authorities both have a claim
Intangibles and services
Getting it right end to end
How international groups price what they exchange between their own companies, and defend it to more than one tax authority.
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