Transfer Pricing for Manufacturing Affiliates in the Czech Republic
Determining arm's length remuneration for a Czech manufacturing affiliate under different transfer pricing models.
Category Contract Manufacturer
Danish Tax Authority Rejects Application of Return on Assets
There are often legitimate concerns with using book value versus market value of assets in applying a Return on Assets approach in transfer pricing. While employing a Return on Costs approach may be a reliable alternative, it must also account for comparability differences in asset intensity.