Rachit Agarwal, Monia Volpato and Uwe Zoellner (DLA Piper) set out the transfer pricing aspects that should be considered during the acquisition process.
Continuing from the previous article on the lifecycle of a transaction series this article considers the key transfer pricing considerations in funding an acquisition. Transfer pricing relates to the pricing of intra-group transactions: for example loans services supply of goods and licensing of intellectual property. This pricing is governed by the arm’s length principle which requires that transactions take place under conditions that are comparable to that of independent enterprises dealing with comparable transactions in comparable circumstances. Transactions that are not in line with the arm’s length principle can have adverse tax and reputational consequences. In turn undertaking a transfer pricing analysis and adhering to the arm’s length principle can allow groups to maximise interest deductibility achieve optimum...
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Rachit Agarwal, Monia Volpato and Uwe Zoellner (DLA Piper) set out the transfer pricing aspects that should be considered during the acquisition process.
Continuing from the previous article on the lifecycle of a transaction series this article considers the key transfer pricing considerations in funding an acquisition. Transfer pricing relates to the pricing of intra-group transactions: for example loans services supply of goods and licensing of intellectual property. This pricing is governed by the arm’s length principle which requires that transactions take place under conditions that are comparable to that of independent enterprises dealing with comparable transactions in comparable circumstances. Transactions that are not in line with the arm’s length principle can have adverse tax and reputational consequences. In turn undertaking a transfer pricing analysis and adhering to the arm’s length principle can allow groups to maximise interest deductibility achieve optimum...
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