The use of value chain analysis in a profit split Cansu Bagran Ilhan
By: Bagran Ilhan, Cansu
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Material type: 
ArticlePublisher: 2018Subject(s): BENEFICIOS | DIVISIÓN | PRECIOS DE TRANSFERENCIA | EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS | PREVENCIÓN
In:
International Transfer Pricing Journal v. 25, n. 4, July/August 2018, p. 273-279Summary: This article provides an introduction to the profit split method (PSM), giving a quick look into its evolution throughout time and explaining how it shall be identified and applied as the most appropriate transfer pricing method, while demystifying the terms "value creation" and "value chain analysis" (VCA) and explaining why they were introduced by the OECD in the Action Plan on Base Erosion and Profit Shifting (BEPS) Actions. The article elaborates on what a VCA should consider, how it should be conducted and what should be the outcome, and addresses the practical aspects of the use of the PSM in a VCA, based on a numerical example in the light of the OECD's recommendations in, inter alia, the OECD Model Tax Convention, the OECD Transfer Pricing Guidelines, the BEPS Actions, discussion drafts and public consultations on the application of the PSM.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | ITPJ/2018/4-3 (Browse shelf) | Available | ITPJ/2018/4-3 |
Disponible únicamente en formato electrónico.
Resumen.
This article provides an introduction to the profit split method (PSM), giving a quick look into its evolution throughout time and explaining how it shall be identified and applied as the most appropriate transfer pricing method, while demystifying the terms "value creation" and "value chain analysis" (VCA) and explaining why they were introduced by the OECD in the Action Plan on Base Erosion and Profit Shifting (BEPS) Actions. The article elaborates on what a VCA should consider, how it should be conducted and what should be the outcome, and addresses the practical aspects of the use of the PSM in a VCA, based on a numerical example in the light of the OECD's recommendations in, inter alia, the OECD Model Tax Convention, the OECD Transfer Pricing Guidelines, the BEPS Actions, discussion drafts and public consultations on the application of the PSM.
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