



How are royalty rates for patents determined in related-party licenses? What are the transfer pricing implications of the transfer of copyrights between related entities?
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what is a non arm's length transaction
- What are the transfer pricing considerations for transactions involving the provision of research services (other than formal R&D) between related entities?
- How can technology be used to streamline the transfer pricing documentation process for non-arm's length transactions across multiple countries? What are the emerging issues in transfer pricing related to the digital economy and the globalization of businesses?
- How is the arm's length commission rate determined in a commissionaire structure? What are the transfer pricing implications of toll manufacturing arrangements?
- What are the transfer pricing considerations for transactions involving the sharing of employees between related entities? How should the compensation for shared employees between related parties be determined under the arm's length principle?
- What are the transfer pricing implications of inventory transfers between related companies? How are the costs of transportation and insurance allocated in cross-border related-party transactions involving tangible goods?
- How can advance pricing agreements (APAs) help manage the tax risks associated with non-arm's length transactions? What is the process for obtaining an advance pricing agreement?
- What are the advantages and disadvantages of the indirect allocation method for intercompany services? How is a reasonable profit margin determined for intercompany services?
- What are the transfer pricing implications of transactions conducted through trusts or foundations involving related parties? How is the arm's length principle applied in the context of partnerships with related partners?
- What are the common audit triggers for non-arm's length transactions by tax authorities?
- What is a non-arm's length transaction?
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