Post by account_disabled on Mar 14, 2024 10:15:29 GMT 5.5
A pursuant to the Decree of the Minister of Finance on the establishment of the Transfer Pricing Forum on 12 January 2018. Actions taken are not binding on the Minister of Finance. According to the nature of the tax interpretation, the interpretation is intended to explain the practical aspects of the use of the resale price method in an effort to increase the tax security of taxpayers. Resale Price Method The resale price method is one of five methods prescribed by transfer pricing regulations for validating transfer prices in comparative analyses. It involves calculating the price for purchasing goods or services from a related entity by subtracting the resale price.
A margin from the sale price of the goods or services to the unrelated entity. This gross profit shall ensure that the dealer covers the direct and indirect costs related to the resale of the subject of the controlled transaction and guarantees a profit commensurate with the functions performed by the entity, the assets involved and the risks arising therefrom. Analysis allows AWB Directory you to determine the functional profile of the entities examined and thus their role. There is no doubt that in the resale method it is more important to compare the functional profile of the entities rather than the functional differences in the products or services offered. In turn, the description.
The method itself suggests that it is most useful when transactions are between related entities, one of which is a manufacturer and the other a distributor. The resale method allows you to verify that the margin levels achieved by an entity in controlled transactions are based on market levels. Comparisons can be made using internal data and external data. Internal data compares the examined transactions to transactions entered into by unrelated entities. External data compares transactions entered into by unrelated entities. Comparable transactions refer to transactions of similar nature. This means that compared entities should be functionally similar. As mentioned earlier in the resale method the functional profile of the entity is important because the profits of a distributor selling goods wholesale.
A margin from the sale price of the goods or services to the unrelated entity. This gross profit shall ensure that the dealer covers the direct and indirect costs related to the resale of the subject of the controlled transaction and guarantees a profit commensurate with the functions performed by the entity, the assets involved and the risks arising therefrom. Analysis allows AWB Directory you to determine the functional profile of the entities examined and thus their role. There is no doubt that in the resale method it is more important to compare the functional profile of the entities rather than the functional differences in the products or services offered. In turn, the description.
The method itself suggests that it is most useful when transactions are between related entities, one of which is a manufacturer and the other a distributor. The resale method allows you to verify that the margin levels achieved by an entity in controlled transactions are based on market levels. Comparisons can be made using internal data and external data. Internal data compares the examined transactions to transactions entered into by unrelated entities. External data compares transactions entered into by unrelated entities. Comparable transactions refer to transactions of similar nature. This means that compared entities should be functionally similar. As mentioned earlier in the resale method the functional profile of the entity is important because the profits of a distributor selling goods wholesale.