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Blogs from November 2015


What the Focus on “Value Creation” Misses

Guy Sanschagrin | November 12, 2015

In his blog post: BEPS - What It All Means, my esteemed colleague Kash Mansori explained that a key to a defensible transfer pricing policy is to align the allocation of taxable income among entities in multinational supply chains with “value creation”. And while this concept introduced under BEPS seems sensible in theory, merely focusing on value creation as the main driver to allocate profit creates tension with the arm’s length standard...