21-06-2011
Taxand publishes article on the Allocation of Risk in Commissionaire Sales Model

In 2010, The OECD issued new transfer pricing guidelines for multinationals restructuring their business model. The new guideline provides new tools for the tax authorities to evaluate and challenge the reallocation of risk and profit that often is the result of such restructuring. Tax payers should provide evidence that the reallocation of profit is commensurate with the reallocation of risk.

This article, published in cooperation between seven Taxand-countries, provides a methodology that enables tax payers and their supervisors to evaluate the arm’s length character of the reallocation.

Click here to download the article.

For more information, please contact Rutger Hafkenscheid at +31 20 301 66 33 or through mail: rutger.hafkenscheid@vmwtaxand.nl.