|
By Antonio Weffer*
One of the most frequently used expressions by transfer pricing practitioners is, depending on the facts and circumstances of the case. It is therefore not a coincidence that you will find this phrase mentioned nearly 100 times within the OECD Transfer Pricing Guidelines.(2) This phrase is part of the transfer pricing jargon to stress the importance of fact gathering and the proper assessment of the functions of the tested party before selecting an appropriate transfer pricing method.
Transfer pricing documentation requirements vary according to jurisdiction and can be complex. Nevertheless, the procedures used to assess the company information are, to a certain extent, harmonised within the EU-OECD countries...
|