Performance guarantee electrónico how to avoid pitfalls and overcome hindrances in a transfer pricing analysis Raffaele Iervolino and Serena Picariello
By: Iervolino, Raffaele
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Contributor(s): Picariello, Serena.
Material type: 
ArticleSubject(s): PRECIOS DE TRANSFERENCIA | EMPRESAS MULTINACIONALES | PROGRAMA INTERNACIONAL DE GARANTÍA DE CUMPLIMIENTO
In:
International Transfer Pricing Journal v. 29, n. 2, 2022, p. 85-92Summary: Performance guarantees are a common form of support used in commercial transactions and their use within multinational enterprises has become increasingly frequent in recent years. This article assesses whether (and to what extent) the methods described in the OECD Transfer Pricing Guidelines in relation to financial guarantees can be used by analogy for the determination of the commission fee related to the provision of a performance guarantee. The authors examine the technical and operational aspects that should be carefully assessed when applying the different methods reported by the OECD to determine transfer prices in line with what third parties would have agreed upon in comparable circumstances and, therefore, with the arm’s length principle.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | ITPJ/2022/2-7 (Browse shelf) | Available | ITPJ/2022/2-7 |
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| ITPJ/2022/2-4 Portuguese APA procedure reviewed | ITPJ/2022/2-5 The long-awaited Circular Letter on Italian transfer pricing documentation | ITPJ/2022/2-6 Profit shifting and comparability | ITPJ/2022/2-7 Performance guarantee | ITPJ/2022/2-8 Transfer pricing and financial transactions | ITPJ/2022/2-9 Digital transfer pricing | ITPJ/2022/3 International Transfer Pricing Journal |
Resumen.
Performance guarantees are a common form of support used in commercial transactions and their use within multinational enterprises has become increasingly frequent in recent years. This article assesses whether (and to what extent) the methods described in the OECD Transfer Pricing Guidelines in relation to financial guarantees can be used by analogy for the determination of the commission fee related to the provision of a performance guarantee. The authors examine the technical and operational aspects that should be carefully assessed when applying the different methods reported by the OECD to determine transfer prices in line with what third parties would have agreed upon in comparable circumstances and, therefore, with the arm’s length principle.
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