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Growing globalisation

05 October 2016 / Andrew Cousins
Issue: 4570 / Categories: Comment & Analysis

How does a growing entrepreneurial business comply with the transfer pricing rules?


  • Eventually expanding businesses will fall within the transfer pricing regime.
  • The size at which a group becomes subject to transfer pricing regulations varies between countries.
  • Transfer pricing compliance requires adherence to the arm’s length principle.
  • OECD Guidelines allow flexibility to identify the most appropriate transfer price.
  • The base erosion and profit shifting project has led to a three-tiered global standard of transfer pricing documentation.


We live in a world of increasing globalisation. And as businesses expand beyond national boundaries they are likely to fall sooner or later within the compliance net of the transfer pricing regulations in the countries where they operate. But several questions need to be considered. At what stage does transfer pricing become a matter of concern for a growing business? In...

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