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Business models for marketing and sales operation – tax implications

Introduction This article provides a high-level overview of some of the common business models used by local entities that are engaged in the distribution, sale and marketing of their group s products and analyses the potential transfer pricing ramifications thereof. The transfer pricing analysis included in this article is predominantly based on Circular 11/2018 (Determination of the appropriate transfer pricing method for activity related to distribution, marketing and sales of a multinational group within the local market),(1) published by the Israeli Tax Authority (ITA). Circular 11/2018 implements the Organisation for Economic Cooperation and Development (OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 (OECD guidelines).

Protections: A Commentary On Trade Secrets In Nigeria - Intellectual Property

Protections: A Commentary On Trade Secrets In Nigeria - Intellectual Property
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OECD Guidance On Pandemic s Impact On Transfer Pricing - Tax

To print this article, all you need is to be registered or login on Mondaq.com. Just in time for the holidays, the OECD has published detailed guidance about the impact of the COVID-19 pandemic on transfer pricing. The guidance has useful information for taxpayers and tax administrations alike. It contains general advice on the application of basic transfer pricing principles during the pandemic, as well as specific advice on four issues: (i) comparability analyses, (ii) allocating losses, (iii) government-assistance programs, and (iv) advance pricing arrangements ( APAs ). The OECD guidance is broadly consistent with comments we made in a prior post about the impact of the pandemic on transfer

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