Tag: Price-setting policy

TPG2022 Chapter II paragraph 2.21

/ Commodity transaction, Comparable uncontrolled price method (CUP), Consistancy, OECD Transfer Pricing Guidelines (2022), Price-setting policy, Pricing formulas, TPG 2022 Chapter II: Transfer Pricing Methods, Traditional transaction methods, Transfer pricing documentation, Transfer pricing methods
In order to assist tax administrations in conducting an informed examination of the taxpayer’s transfer pricing practices, taxpayers should provide reliable evidence and document, as part of their transfer pricing documentation, the price-setting policy for commodity transactions, the information needed to justify price adjustments based on the comparable uncontrolled transactions or comparable uncontrolled arrangements represented by the quoted price and any other relevant information, such as pricing formulas used, third party end-customer agreements, premia or discounts applied, pricing date, supply chain information, and information prepared for non-tax purposes ... Read more

TPG2017 Chapter II paragraph 2.21

/ Commodity transaction, Comparable uncontrolled price method (CUP), Consistancy, OECD Transfer Pricing Guidelines (2017), Price-setting policy, Pricing formula, Traditional transaction methods, Transfer pricing documentation, Transfer pricing methods
In order to assist tax administrations in conducting an informed examination of the taxpayer’s transfer pricing practices, taxpayers should provide reliable evidence and document, as part of their transfer pricing documentation, the price-setting policy for commodity transactions, the information needed to justify price adjustments based on the comparable uncontrolled transactions or comparable uncontrolled arrangements represented by the quoted price and any other relevant information, such as pricing formulas used, third party end-customer agreements, premia or discounts applied, pricing date, supply chain information, and information prepared for non-tax purposes ... Read more