It can be difficult to determine the relative value of the contribution that each of the associated enterprises makes to the relevant profits, and the approach will depend on the facts and circumstances of each case. The determination might be made by comparing the nature and degree of each party’s contribution of differing types (for example, provision of services, development expenses incurred, assets used or contributed, capital invested) and assigning a percentage based upon the relative comparison and external market data. See section C.5 for a discussion of how to split the relevant profits.
TPG2018 Chapter II paragraph 2.151
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Contribution analysis, Profit split method (PSM), Relative value of contributions, Relevant profits, Transfer pricing methods
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