The global allocation of multinational profits

Prices and transparency are just two key considerations when it comes to the complexities involved in allocating the global profits of MNCs across the jurisdictions in which they operate

Recent developments in the global tax arena have highlighted the complexities involved when allocating the global profits earned by multinational corporations (MNCs) across the jurisdictions in which they operate. Key to this allocation is the (i) price charged (or transfer price) for the purchase and sale of goods/services between members of the same group, and (ii) the level of substance which those entities have in the jurisdictions in which they operate.

Guidelines on ...