Jurisdictions 1
This jurisdiction's transfer pricing rules deviate significantly from international standards, including the OECD Guidelines, as there are no profit-based methods, and the concept of a functional and risk analysis is not included in the local TP rules. (Claire)
What is Brazil?
The full name of the tax authority in Australia. (Mariel)
What is the Australian Taxation Office ("ATO")?
The world's most advanced AI tax and transfer pricing expert. (Mariel)
Who is Fiona?
This Profit Level Indicator is most commonly used when the tested party in a CPM/TNMM is a service provider. (Mike Q)
What is the Net Cost Plus ratio?
Their goal is to shape policies that foster prosperity, equality, opportunity and well-being for all. (Neha)
What is the Organization for Economic Co-operation and Development ("OECD")?
This jurisdiction requires a single year, full range analysis. (Claire)
What is Canada?
The abbreviation of the tax authority in Italy. (Mili DC)
What is ADE (Agenzia delle Entrate)?
This city along the river is home to XBS's Argentina office. (Mili DC)
What is Rosario?
This Profit Level Indicator is most commonly used when the tested party in a CPM/TNMM is a distributor. (Mike Q)
What is the Operating Margin?
This allows the taxpayer and the tax authority to avoid future transfer pricing disputes by entering into a prospective agreement, generally covering at least five tax years, regarding the taxpayer's transfer prices. (Mihai)
What is an Advance Pricing Agreement ("APA")?
This jurisdiction, also home to a city known as “Little Paris”, requires including the Group information in the Local File. (Mihai)
What is Romania?
In India, Rule 10CA prescribes use of the 35th percentile to 65th percentile as the arm’s-length range if the method being followed is CUP, resale price, cost-plus or TNMM and there are this many or more entries in the data set. (Gabe)
What is six?
This person's middle name is Gray. (Dan)
Who is Adam Sandford?
This PLI is calculated by dividing the company's gross profits by the operating expenses, to derive a general indication of the company's profitability and financial health. (Neha)
What is the Berry Ratio?
The number of members in the OECD. (Dan)
What is 36?
This jurisdiction, with the world's highest consumption of red meat, requires the local entity to be the tested party. (Dan)
What is Argentina?
This jurisdiction provides taxpayers the opportunity to use pre-approved interest rates published by the tax authority for intercompany loans and advances. (Claire)
What is the United States?
Has a Ph.D. in Economics. (Dan)
Who is Maggie Tian?
A method used to analyze the manufacture, assembly, and production of tangible goods within the same product category, wherein the gross margin of the manufacturer involved in the controlled transaction is compared with the gross margin of manufacturers in the comparable uncontrolled transaction. (Neha)
What is Cost Plus Method?
External third-party costs that an entity incurs on behalf of a related affiliate or third-party customer in connection with its business activities. (Gabe)
What are pass through costs?
In this jurisdiction, where Jambo means Hello, applying a 75% independence screen when searching for comparable companies is common practice. (Mihai)
What is Kenya?
This jurisdiction uses a pooled range for TNMM, meaning it takes the interquartile range of all three years of observations. (Mike Q)
What is Russia?
The day on which our current solution went live. (Mili DC)
When is May 10th?
An agreement under which controlled parties split the costs of developing one or more intangibles in proportion to each party’s share of reasonably anticipated benefits from the intangibles. (Claire)
What is a cost sharing arrangement?
The financial transaction arrangement through which a business sells its accounts receivable (i.e., invoices) to a third party at a discount. (Mili DC)
What is factoring?