Expert Resources

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Paul Sutton

Intercompany agreements and the OECD Guidance on Transfer Pricing Documentation and Country-by-Country Reporting

It is no surprise that the OECD Guidance on Transfer Pricing Documentation and Country-by-Country Reporting issued on 16 September 2014 confirms that intercompany agreements (and the legal framework generally) play an important part in the transfer pricing documentation of a multinational enterprise. Some of the specific references to intercompany agreements …