Transfer pricing by it's very nature is complex. Our videos addresses some of the more commonly encountered TP issues and explains in clear, easy to understand terms. If you have a more specific query that we have not addressed, please get in touch.
Can mark up be reduced? Can the service be suspended? Benefit test issues if services provided remotely? Can abnormal expenses be excluded?
Can the royalty be suspended? Can the royalty be reduced? Issues with service provider?
Why high risk and why attention? Because a contract is sufficient to originate the transaction. As a result tax authorities are experiencing tax leakages as a result of excessive interest expenses deduction and excessive interest income place in low tax or no tax countries.