Paul Sutton gives a detailed overview of contractual allocation of risk in transfer pricing. The discussion looks at:
- The definition of risk, for transfer pricing purposes
- What the legal documentation is trying to achieve
- The role of contracts in allocating risk
- Examples of contractual clauses that deal with risk
- The other factors that must be considered
- The potentially serious consequences of getting it wrong
- Common mismatches between TP documentation and agreements
- Key takeaways for transfer pricing professionals.