Considerations before choosing method transfer of pricing
Who obtains benefit
First of all need to be determined as according to case is upper, whosoever obtaining benefit from the transaction. Explains the obtaining benefit from SOP is SUBSIDICO-2 employing John Doe. However, possible SUBSIDICO-1 also obtains its(the benefit if(when John Doe is side structurally held responsible to SUBSIDICO-2 but permanent is in control of performance in SUBSIDICO-1.
This thing earns is just happened if(when SUBSIDICO-2 to give service to SUBSIDICO-1 or in the case of doing of posting with between SUBSIDICO-1 and SUBSIDICO-2 to John Doe.
So for example SUBSIDICO-2 gives service to SUBSIDICO-1 by employing John Doe as main character ( as according to its(the expertise). While in SOP mentioned, John Doe is employee who is obtaining benefit from the plan. In the case of that way for applying of transfer of pricing must be corrected reading the relation of transaction between PARENTCo with and SUBSIDICO-2 place of John Doe works and transaction between SUBSIDICO-2 with SUBSIDICO-1 and other affiliate. Encumbering billed for by PARENTCo to SUBSIDICO-2 in the relation with exercise of SOP to John Doe becomes cost for the agenda of vesting of service to affiliated company in the group. In the case of that way hence who enjoys transaction SOP ( beside Jihn Doe) becoming not relevant again.
Who obtains benefit
First of all need to be determined as according to case is upper, whosoever obtaining benefit from the transaction. Explains the obtaining benefit from SOP is SUBSIDICO-2 employing John Doe. However, possible SUBSIDICO-1 also obtains its(the benefit if(when John Doe is side structurally held responsible to SUBSIDICO-2 but permanent is in control of performance in SUBSIDICO-1.
This thing earns is just happened if(when SUBSIDICO-2 to give service to SUBSIDICO-1 or in the case of doing of posting with between SUBSIDICO-1 and SUBSIDICO-2 to John Doe.
So for example SUBSIDICO-2 gives service to SUBSIDICO-1 by employing John Doe as main character ( as according to its(the expertise). While in SOP mentioned, John Doe is employee who is obtaining benefit from the plan. In the case of that way for applying of transfer of pricing must be corrected reading the relation of transaction between PARENTCo with and SUBSIDICO-2 place of John Doe works and transaction between SUBSIDICO-2 with SUBSIDICO-1 and other affiliate. Encumbering billed for by PARENTCo to SUBSIDICO-2 in the relation with exercise of SOP to John Doe becomes cost for the agenda of vesting of service to affiliated company in the group. In the case of that way hence who enjoys transaction SOP ( beside Jihn Doe) becoming not relevant again.
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