


What role do economic analysis and benchmarking studies play in justifying the pricing of non-arm's length transactions?
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what is a non arm's length transaction
- How should the rental or usage fees for shared facilities or equipment between related parties be determined under the arm's length principle?
- What are the transfer pricing implications of the cessation of business activities by a related entity? How are the tax consequences of the termination of intercompany agreements determined?
- What types of training and awareness programs can help employees understand the importance of arm's length pricing in related-party transactions?
- What are the transfer pricing implications of transactions involving the transfer or licensing of pharmaceutical intellectual property between related parties?
- How are the processing fees determined in related-party toll manufacturing agreements?
- How do joint ventures between related parties address transfer pricing issues? What are the transfer pricing implications of the assignment of intellectual property between related parties?
- How does the cost-plus method work for non-arm's length transactions? What are the advantages and disadvantages of using the cost-plus method for non-arm's length transactions?
- What are the limitations of relying solely on third-party data for transfer pricing analysis?
- How do tax authorities evaluate the benefit test for intercompany services? What are the different methods for allocating costs in shared service arrangements between related parties?
- What are the transfer pricing implications of thin capitalization rules in relation to related-party debt?
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