173. Competent authorities should identify the materiality of the transfer pricing in the context …

Competent authorities should identify the materiality of the transfer pricing in the context of trading book items by focusing on the transfer pricing arrangements that meet the following conditions:

• a. they involve at least one entity of the group that is established outside of the Union and for which the highest level of consolidation is outside the Union;
• b. they are based on a transaction profit method (TPM) – or any similar practice that would be economically equivalent – in accordance with which the profits and losses relating to positions owned by several entities are re-distributed across those entities on the basis of the marginal contribution ‘m’ of each entity towards key -metrics set out in the pricing arrangement.

1. Yleiskatsaus

1.1 Viittaukset

1.2 Tunnistetut vaatimukset

1.3 Liittyvät standardit

2. Tunnistetut vaatimukset

3. Liittyvät standardit

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