

What are the challenges in determining the arm's length value of marketing intangibles in non-arm's length transactions?
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what is a non arm's length transaction
- What documentation is typically required to support the pricing in a non-arm's length transaction?
- What are the transfer pricing considerations for transactions with state-owned enterprises? How does the ownership structure of the parties influence the analysis of a transaction's arm's length nature?
- What are the common mistakes companies make in pricing non-arm's length transactions? How can companies improve their processes for determining and documenting arm's length pricing?
- How are the tax consequences of hybrid mismatches involving related parties addressed under international tax rules?
- How can a company conduct a self-assessment of its transfer pricing compliance for non-arm's length transactions?
- What are the transfer pricing considerations for transactions involving the provision of after-sales service and support between related entities?
- What are the transfer pricing implications of transactions involving the provision of administrative support services between related entities?
- How are profits attributed to a permanent establishment under the arm's length principle? What are the transfer pricing implications of transactions between a head office and its branch?
- What are the factors considered when applying the profit split method?
- What are the transfer pricing implications of cash pooling arrangements among related entities? How are intercompany insurance arrangements scrutinized for arm's length principles?
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