Handbuch Verrechnungspreise
2. Aufl. 2012
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S. 165 This article provides a brief update of the work and the main realisations of the EU Joint Transfer Pricing Forum (EU JTPF) since 2010 until October 2011. A specific focus will be put on the work of the EU JTPF on Small and Medium-sized Enterprises (SMEs). For an overview of the previous work and realisations of the EU JTPF, the author refers to earlier publications.
1. Low value adding intra-group services
On low value adding intra-group services the EU JTPF has produced and disclosed an extensive report. The paper builds further on the principles as laid down in chapter VII of the OECD Transfer Pricing Guidelines and focuses on services of an administrative nature, being auxiliary to the business of the recipient. This report has been adopted by the European Commission on January 25, 2011 and by the EU Council on May 17, 2011.
The core nature of the envisaged intra-group services is that, whilst required, these services are of a routine nature and are not generating high value adding to either the provider or the recipient. Furthermore the paper does not focus on direct charge services nor does it address Cost Contribution Arrangements (CCAs). CCAs are currently being discussed by...