Vesting of intercompany service affiliated in the relation with SOP is not done but an or more employee is entering in program SOP, works for company multiple in group. PARENTCO then cost allocation to involving affiliated company, for the agenda of SOP. In this case, cost allocation must be related to fee which ought to be received by the employee to obtain number of fair fees.
Comparison with transaction that is is not is influenced [by] related parties
One of important key for the agenda of applying of method transfer of pricing is do comparison of transaction that is conspecific with transaction done between party(sides that is is not has related parties. Looks for comparison with independent transaction in the relation with example is upper to difficult to because if only the transaction there is hence stock taken as option object is stock from company employing the employee. If company is public company hence the price of stock at the time of option is executed to easy to be known, but if non the company public company hence its(the value will not be knowable swiftly.
Thereby not possibly does comparison with transaction that is is not is influenced [by] related parties for transaction in the form of SOP.
Based on breakdown of above mentioned hence to be able to do analysis transfer of better pricing pointed to characteristic from financial and commercial relationship between PARENTCo with SUBSIDICO-1 and SUBSIDICO-2 in consequence of SOP. As According To OECD TRANSFER PRICING GUIDELINES some things that need to be corrected reading to apply method transfer of pricing applied by attention that is:
a) Marking from SOP given;
b) Function analysis;
c) Conditions in contract;
d) Economic factor;
e) Business strategy.
Comparison with transaction that is is not is influenced [by] related parties
One of important key for the agenda of applying of method transfer of pricing is do comparison of transaction that is conspecific with transaction done between party(sides that is is not has related parties. Looks for comparison with independent transaction in the relation with example is upper to difficult to because if only the transaction there is hence stock taken as option object is stock from company employing the employee. If company is public company hence the price of stock at the time of option is executed to easy to be known, but if non the company public company hence its(the value will not be knowable swiftly.
Thereby not possibly does comparison with transaction that is is not is influenced [by] related parties for transaction in the form of SOP.
Based on breakdown of above mentioned hence to be able to do analysis transfer of better pricing pointed to characteristic from financial and commercial relationship between PARENTCo with SUBSIDICO-1 and SUBSIDICO-2 in consequence of SOP. As According To OECD TRANSFER PRICING GUIDELINES some things that need to be corrected reading to apply method transfer of pricing applied by attention that is:
a) Marking from SOP given;
b) Function analysis;
c) Conditions in contract;
d) Economic factor;
e) Business strategy.
Tidak ada komentar:
Posting Komentar