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TP Keywords

A

Abnormal act of management (6)
Above or below the gross profit line (1)
Absent tax benefits (1)
Abuse of discretion (1)
Abuse of law (1)
Abusive tax avoidance (3)
Access to funding (1)
Access to workforce in place (2)
Accounting consistency (11)
Accounting standards (11)
Accounting valuation (1)
Accounts receivable (1)
Accurate delineation (17)
Acquired vs self-developed intangibles (2)
Acquisition of intellectual property (2)
Acquisition of shares (1)
Acquisition of subsidiaries (1)
Active pharmaceutical ingredient (4)
Acts as nominee (1)
Actual arrangement vs Contractual arrangement (2)
Actual conduct (4)
Actual control (2)
Actual outcome/returns (5)
Actual situation as a subsidiary (1)
Actual transaction (3)
Additive approach (3)
Adecco (2)
Adjustment for depreciation/amortisation (2)
Adjustment for start-up cost (1)
Adjustment for stock options and pensions (1)
Adjustment for termination costs (1)
Adjustments for accounting consistency (1)
Adjustments for differences in capital functions assets risks (1)
Administrative-/compliance burden (8)
Administrative function (1)
Administrative procedures (2)
Advance cross border rulings (1)
Advance pricing arrangement (APA) (73)
Advertising (2)
Advertising campaign (1)
Advisor liability (1)
Ad words (1)
Affect the arm’s length price (1)
After-sales services or sales of spare parts (1)
Agency sales (3)
Agent (2)
Aggregated data (1)
Aggregated transactions (17)
Aggregation of the intangibles (2)
Agreement at the outset (3)
Agressive tax planning (1)
Agressive Tax Planning Indicator (2)
Agricultural products (1)
Akin to a sale (2)
Alienation of property (1)
Allocation key (8)
Allocation of capital/equity (1)
Allocation of cost between supplier and purchaser (1)
Allocation of costs (2)
Allocation of income (1)
Allocation of indirect expenses (1)
Allocation of losses (3)
Allocation of risk (3)
Allocation of synergy benefit (9)
Altera (1)
Amortisation (1)
Amount charged (2)
Amount of the loan (1)
AMP (advertising marketing promotion) (1)
Analysis of risk (56)
Anti-dumping duties (1)
Anti Arbitrage Rules (1)
Anticipated benefits (1)
Anticipated cost savings (1)
Anticipated returns (4)
AOA (5)
APA (2)
Apple (1)
Application of Profit split method (9)
Application of the CUP method (2)
Application of the simplified approach (7)
Applied consistently over the lifetime (1)
Applies generally (1.140) (3)
Approved Issuer Levy (1)
Arbitrary and capricious (1)
Arbitration (3)
Arbitration Convention (1)
Arm’s length outcomes (1)
Arm’s length principle (8)
Arm’s length remuneration (2)
Arm’s length range (21)
Article 4 (1)
Article 5 (2)
Article 7 (5)
Article 9 (20)
Article 12 (1)
Artificial arrangement (2)
Artificial arrangements (4)
Artificial Avoidance of PE (1)
Artificial corporate structures (1)
Artificial separation of intangibles (1)
Assembled workforce (8)
Assembling (1)
Asset based splitting factors (4)
Asset management (1)
Assets actually used (1)
Asset valuation (1)
Assignment of income (1)
Assist with factory start-up (1)
Assume risk prior to materialisation (2)
Assumption of financial risk (1)
Assumption of risk (22)
Asymmetrical splits (1)
Asymmetrical splits of profits and losses (9)
Asymmetry of information (3)
ATAD (1)
ATAP (1)
ATO (1)
ATP (1)
At the time of the transaction (1)
Attribution of profit (4)
Attribution of Profits to Permanent Establishments (1)
Audit (1)
Audit cost (1)
Audit practices (5)
Audit resources (1)
Automatic exchange of information (1)
Availability of information (3)
Availability of reliable information (4)
Average external financing rate (1)

B

C

Calculation of Discount Rates (1)
Cameco (1)
Cancellation of APA (1)
Cannot be transferred without transferring the other (1)
Capability to make decisions (1)
Capacity to assume risks (1)
Capacity utilization risk (1)
Capital in nature (1)
Capitalisation of costs (1)
Capital structure (1)
Capital support method (1)
Capital transactions (1)
CAPM (1)
Captive insurance (42)
Cash box (1)
Cash pool (54)
Cash pool guarantees (2)
Cash pool leder (15)
Cash pool members (4)
Cash pool or loan (2)
Catagories of intangibles (17)
Cayman Islands (1)
CbCR (1)
CCA documentation (3)
CCA is a contractual arrangement (1)
CCA termination (1)
CCCTB (2)
Centralisation of legal ownership of intangibles (4)
Centralised business model (1)
Centralised purchasing (1)
Centralised services (1)
Central tendency (3)
CFA (4)
CFC (1)
CFC loan guarantee (1)
Challenges analysing intangible transactions (1)
Chance in a transaction (1)
Changes in the membership of a CCA (2)
Characterisation of the transaction (1)
Characteristics of property/service (3)
Check-the-Box (2)
Cherry picking (2)
Choice of tested party (1)
Circular 12/2018 (2)
Circular arrangement (1)
Citybank (1)
Civil (or administrative) penalties (2)
Civil law (1)
CJIP (1)
Clearance agreement (1)
Clerical error (1)
Closely related risks (4)
Closing agreement (2)
Co-branding (1)
Coffee machines and capsules (1)
Collateral (1)
Colourable device (2)
Combination of intangibles (1)
Combined ratio and return on capital (2)
Combined Taxable Income (CTI) (1)
Combined transactions (3)
Commentaries (1)
Commercial and financial relation (9)
Commercial considerations (2)
Commercial databases (6)
Commercial judgement (1)
Commercial justification (2)
commercial legislation or case law (1)
Commercially irrational (13)
Commercial rationality (16)
Commercial rationality of a restructuring as a whole (1)
Commercial reality (1)
Commissionaire (10)
Commissionaire arrangement (2)
Commission based model (1)
Commission expenses (1)
commodities (1)
Commodity exchange market (1)
Commodity Exchange Prices (1)
Commodity transaction (24)
Common law (1)
Common understanding (1)
Company-wide basis (2)
Comparability (39)
Comparability adjustments (41)
Comparability analysis (209)
Comparability analysis – 9 step process (10)
Comparability defects (10)
Comparability factors (23)
Comparability of intangibles (12)
Comparability study (1)
Comparable circumstances (1)
Comparable companies (2)
Comparable cost basis (4)
Comparable data (5)
Comparable in all characteristics other than the product (1)
Comparable profits method (1)
Comparable profit split method (2)
Comparable royalty rates (2)
Comparables (10)
Comparable search (1)
Comparables search (8)
Comparable Uncontrolled Price (CUP) Method (1)
Comparable uncontrolled transaction (CUP) (23)
Comparable with same type of intangibles (1)
Comparing to other controlled transactions (2)
Comparison of controlled transactions with other controlled transactions (1)
Compensating adjustment (6)
Compensating transactions (1)
Compensation for services (1)
Compensation for services of seconded employees (1)
Compensation for termination or renegotiation (29)
Competent authority procedure (1)
Competing incentives (1)
Complex taxation issues (1)
Compliance (1)
Compliance costs (4)
Compliance efforts (1)
Compliance issues (4)
Comport as closely as possible (1)
Concentration of functions (1)
Conclude contracts on behalf of (1)
Conduct of the parties (10)
Conduct was inconsistent (1)
Conduit company (2)
Conduit jurisdictions (2)
Confidential documentation (2)
Confidentiality (1)
Consistancy (2)
Consistent in application of the quoted price (1)
Consolidation requirement (2)
Constructive dividends (1)
Contemporaneous documentation (9)
Contemporaneous information (7)
Contemporaneous uncontrolled transactions (3)
Contingent payments (2)
Continued use of intangibles (1)
Continuous losses (29)
Contract manufacturing (19)
Contract R&D (10)
Contractual agreements (1)
Contractual arrangement (2)
Contractual assumption of inventory risk (1)
Contractual Assumption of risk (9)
Contractual assumption of risk not followed in practice (1)
Contractual rights (3)
Contractual terms (13)
Contract vs Conduct (1)
Contributed no value (1)
Contribution analysis (11)
Contribution in the form of intangibles (1)
Contribution of other group members (1)
Contribution proportionate to expected benefits (3)
Control (1)
Control functions (12)
Controlled Foreign Companies (CFC) (2)
Controlled Foreign Corporation (CFC) (4)
Controlled transaction (1)
Controlling performance of functions (2)
Control of economically significant risk (1)
Control of the legal owner (2)
Control over financial risk (1)
Control over risk (39)
Conversion of full-fledged distributors (9)
Conversion of full-fledged manufacturers (2)
Converted into a commissionaire (3)
Converted into a sales agent (1)
Converted into a toll manufacturer (1)
Convertible loan (1)
Convertible Note (1)
Convey economic value (1)
Cooperation between tax and customs administrations (1)
Copyrighted software code (1)
Core business (1)
Corporate bonds (1)
Corporate synergies (1)
Corporate tax incentives (1)
Corresponding adjustment (53)
Cost-based indicators (1)
Cost approach (4)
Cost as measure for relative value of contribution (1)
Cost base (5)
Cost based splitting factors (5)
Cost Contribution Arrangement (CCA) (78)
Cost in current year and previous years (1)
Cost of borrowing (1)
Cost of closing (4)
Cost of contributions (1)
Cost of distribution functions (1)
Cost of functions (1)
Cost of funds (3)
Cost of funds-method (1)
Cost of leasing vs ownership (1)
Cost of MAP (1)
Cost of marketing activities (2)
Cost plus (3)
Cost plus mark up (2)
Cost plus method (32)
Cost savings (1)
Cost savings objective factored into remuneration (1)
Cost sharing agreement (1)
Cost vary over time (1)
Cost vs value (1)
Country-by-Country Reporting (8)
Coupon payments (1)
Covenants (4)
COVID-19 (112)
COVID-19 specific costs (17)
Credit arrangement (1)
Credit default swaps (3)
Credit rating (5)
Credit risk (2)
Credit risk analysis (1)
Criminal penalties (1)
Cross-border financing arrangements (1)
Cross-guarantee agreement (2)
CSA (1)
CSA regs (1)
CTI (1)
Cum-ex (2)
CUP (9)
CUP method (58)
CUP method preferred (2)
CUPs from transactions prior to acquisition (1)
Currency risk (2)
Current contributions (1)
Current contributions at cost (1)
Current value (1)
Customer lists (2)
Customs (1)
Customs costs (1)
Customs valuations (3)
CUT method (3)
Cyprus (1)

D

DAC (1)
Danone (1)
Databases (7)
Data difficult to obtain (1)
Data from other crises (1)
Data from years after the transaction (1)
DCF model (31)
De-specialisation of operations (1)
Debt (1)
Debt factoring (2)
Debt instruments (1)
Decision making (1)
Decision making functions (8)
Deduction (1)
Deductive approach (3)
Deemed dividend (2)
Deemed interest (1)
Deemed international transaction (1)
Deemed pricing date (1)
Deemed services transaction (1)
Deferrals of payments (1)
Definition of captives (6)
Definition of intangible (1)
Definition of risk (1)
Degree of comparability (1)
Delaware (1)
Deliberate concerted actions (19)
Deliberate inaccuracies (1)
Delineation (98)
Delineation of Business Restructurings (15)
Delineation of cash pooling arrangements (4)
Delineation of CCAs (2)
Delineation – Substance over Form (1)
Demand additional information (1)
DEMPE functions (34)
Denominator – capable of being measured (1)
Denominator – costs (4)
Denominator – employees (1)
Denominator – full costs (2)
Denominator – independent from controlled transactions (1)
Denominator – operating assets (3)
Denominator – operating expenses (2)
Denominator – sales (1)
Denominator materially affected by controlled transaction (1)
Dependent agent (1)
Derivative contracts (1)
Detailed information on the foreign associated (3)
Determination of costs (1)
Determined at the outset (2)
Determining profit to be split (3)
Deutsche Bank (1)
Developing countries (1)
Developing documentation rules (1)
Developing justifications after the fact (1)
Development CCAs (4)
Development risk (1)
Diagnostic ratios (2)
Did not reflect economic reality (3)
Difference in volumes (1)
Differences in capacity utilisation (1)
Differences in characteristics (1)
Differences in competitive position (1)
Differences in markets (1)
Differences in the level and types of expenses (1)
Differences in the nature of the intangibles (1)
Differences materially affecting price (5)
Difference to party in control of risk (1)
Different measures of profit (4)
Different Method (2)
Difficult cases where no one approach is conclusive (1)
Difficulties in placing the corresponding adjustment (1)
Digital economy (28)
Digital presence (1)
Digital products or services (1)
Digital Service Tax (DST) (4)
Digital Service Tax (DTS) (1)
Direct-charge method (2)
Direct costs (1)
Disaggregation of package contract (2)
Disallowed deduction (8)
Discount (4)
Discounted Cash Flow (4)
Discount rate (1)
Disguised expenses (1)
Disguise true nature of transaction (1)
Disposal of marginal production (1)
Dispute prevention (1)
Dispute resolution (2)
Disregarding the transaction (15)
Distorted by controlled transactions (1)
Distressed asset/debt (1)
Distribution (5)
Distribution agreement (6)
Distribution contract (1)
Distribution rights (1)
Distribution services (1)
Distributor (3)
Divergence of interests between the parties (1)
Diverted Profits Tax (1)
Dividend or interest (2)
Dividends (3)
Dividends received deduction (1)
Division of profits expected form independent (1)
Documentation (9)
Documentation denied (2)
Documentation request (4)
Documentation Requirements (3)
Domestic legislation (2)
Domestic tax compliance practices (1)
Double Dipping (2)
Double Irish Dutch sandwich (1)
Double non taxation (4)
Double taxation (6)
Double tax treaty (8)
Downsizing of operations (1)
Downward adjustment (1)
DTA (1)
Dual-listed company arrangement (1)
Dual resident companies (1)
Due and proper case handling (1)
Duplicated services (1)

E

Eaton (1)
EBITDA (1)
EBIT margin (2)
Economic/product cycle (1)
Economic activities (1)
Economically insignificant risks (1)
Economically neutral to take on (or lay off) risk (3)
Economically relevant characteristics (28)
Economically significant risk (11)
Economic And Juridical (1)
Economic circumstances (10)
Economic consequences (3)
Economic double taxation (1)
Economic modelling (3)
Economic ownership (2)
Economic significance of risk (3)
Economic substance (3)
Economies of scale (3)
effective control (1)
Effective place of management (3)
Effective tax rate (2)
Effect of group membership (7)
Effects of breached critical assumptions (5)
Efficiencies or inefficiencies (2)
Eliminate need for cross-licensing arrangements (1)
Elimination of interest income and expenses (1)
Elimination of less comparable (1)
Embedded intangibles (1)
Employee compensation (1)
Employee costs (1)
Employee remuneration (1)
Employee stock options (4)
Empty shell (1)
Enhancement of value (5)
Enterprise Resource Planning (1)
Entitelment to part of return (6)
Entry withdrawal termination (7)
Equal footing (1)
Equity or Debt/Loan (26)
Establishing a transaction (1)
Estimated assessment (1)
Estimate taxable income (2)
EU (5)
EU Commission (1)
European anti-avoidance doctrine (1)
EU state aid rules (14)
Every effort to determine pricing (1)
Examination practices (3)
Example (12)
Example – asset owner without control over risk (3)
Example – business restructuring of full-fledged distributor (1)
Example – CCA balancing payments (2)
Example – choice of tested party (1)
Example – clarifying written terms of contract (1)
Example – commercially irrational transaction (2)
Example – contract manufacturing (1)
Example – control over risk (1)
Example – conversion to limited risk (2)
Example – conversion to limited risk distributor (1)
Example – Cost Plus Method (1)
Example – cost plus method accounting for general cost (1)
Example – cost plus method contract manufacturing (1)
Example – cost plus method contract R&D (1)
Example – cost plus method efficiencies in manufacturing (1)
Example – CUP unbranded coffee beans (1)
Example – CUP volume discount (1)
Example – financial guarantee (2)
Example – financial guarantees (5)
Example – funding intangibels (1)
Example – highly specialised engineering (2)
Example – investment based on manufacturing contract (3)
Example – Limited risk distributor (Pharma) (1)
Example – long term loan to manage short-term needs (1)
Example – moving production to low cost country (2)
Example – registred owner of patents (5)
Example – right to all future development for lump sum (1)
Example – risk-adjusted rate of return (1)
Example – risk-free rate of return (1)
Example – risk assumption contract R&D (1)
Example – setting up central procurement operation (1)
Example – termination of valuable contract (1)
Example – TNMM top quality vs generic medium quality (1)
Example – transaction not been identified by the MNE (1)
Example – transfer of intangibles and legal ownership (3)
Example – unable to service the loan (1)
Example – written terms vs conduct of the parties (1)
Example 1 (1)
Example 1 – Cash pool leader (5)
Example 1 – group member rating vs stand alone rating (3)
Example 1 – implicit support (3)
Example 2 – Cash pool leader (5)
Example 2 – loan guarantee vs incidental benefits (1)
Example 3 (1)
Example 3 – central purchasing manager (widgets) (1)
Example 4 – negotiate discount on behalf of group (widgets) (1)
Example 5 – widget acquisition by shared service center (4)
Example 6 (1)
Example 7 (1)
Example 8 (1)
Example 13 (1)
Example 14 (1)
Example 16 (1)
Example 17 (2)
Examples (1)
Examples 1 to 6 (1)
Example Services (1)
Examples on HTVI (1)
Examples on LVAS (1)
Example TNMM (1)
Example Warranty (1)
Ex ante (9)
Ex ante/Ex post (1)
Exceptional circumstances (4)
Exceptional costs (9)
Excessive debt (3)
Excessive interest (3)
Excess profit exemption (1)
Excess profit scheme (1)
Exchange controls (6)
Exchange of information (1)
Exchange rates (1)
Exclusive distribution right (1)
Exclusive distribution rights (2)
Exclusive licence (1)
Exclusive right (1)
Exercise of good judgment (2)
Exercising control (1)
Existing R&D workforce (1)
Exit taxation (2)
Expectations of future profits (1)
Expected benefits (6)
Expected future profits (1)
Expected loss approach (1)
Expected mutual and proportionate benefit (3)
Expected vs actual results (1)
Expensive marketing strategy (1)
Explicit guarantee (2)
Exploitation of intangibles (1)
Exploration services (1)
Ex post (8)
Extent of the disruption (1)
External comparables (18)
External market data (1)
External market forces (2)
Extraordinary costs (1)
Extraordinary income and costs (1)
Extreme Default Risk loan (EDR) (2)
Extreme results (3)

F

G

H

Hard-to-value intangibles (HTVI) (30)
Harmful tax practices (4)
Hazard risks (3)
Headcount (1)
Hearings (1)
Hedging (8)
Hidden deposit (1)
Hidden distribution of profits (9)
Hidden inter-company service (1)
Hierarchy of methods (3)
High degree of integration (2)
High degree of inter-dependency (1)
High degree of taxpayer culpability (1)
High level of integration (1)
Highly integrated (10)
Highly integrated activities (1)
Highly inter-dependent activities (1)
Highly uncertain (2)
Hindsight (11)
Holding the parties to the written contract (1)
Hong Kong (1)
How value is generated (1)
HTVI also applies to other transactions (1)
Huhtamäki (1)
Hungary (1)
Hybrid (1)
Hybrid Entity (1)
Hybrid loan (4)
Hybrid Mismatch (2)

I

ICAR (1)
Identification of risk (6)
Identification of transaction (1)
Identifying intangibles (28)
Illegal state aid (1)
Illegal tax benefit (2)
Impairment loss (1)
Implementation guide (1)
Implementation of CbC reporting (15)
Implementation of Master and Local file (1)
implement the outcome of a CCA (1)
Implicitly assumed risks (1)
Implicit support/guarantee (12)
Import/Export restrictions (1)
Important decisions (1)
Improving long-term profit (1)
Inappropriate use of method (1)
In between reservation prices (1)
Inbound distribution arrangements (1)
Incidental benefits (6)
Income based approach (1)
Inconsistent documentation (1)
Inconsistent positions pre- and post- pandemic (1)
Increased future profits (1)
Incremental sales (1)
Indemnification (6)
Indemnification clause (7)
Indemnification for change in arrangements (2)
Independent distributors (1)
Indirect-charge method (3)
Indirect costs (1)
Indirect transfer of profits abroad (2)
Individual benefits (1)
Industry average (1)
Industry averages (1)
Industry practices (1)
Industry sector (1)
Inflation rates (1)
Information (1)
Information from after the transfer (1)
Information in foreign companies (2)
Information on tax planning arrangements (1)
Information outside country (1)
Infrastructure or operational risks (1)
Insignificant intangibles (1)
Insufficient data (2)
Insurance (1)
Insurance cost (1)
Intangible-related criteria (1)
Intangibles (277)
Intangibles used by the reseller (1)
Intangibles used in performance of services (5)
Intangibles used in sales of goods (6)
Integrated businesses (1)
Intellectual property (2)
Inter-company agreements (1)
Inter-company loan (24)
Interest (4)
Interest and royalty directive (1)
Interest deductibility (2)
Interest deduction (14)
Interest free loan (8)
Interest limitation (4)
Interest of both parties (1)
Interest rate (35)
Interest swap rates (1)
Intermediary activities (2)
Intermediary Company (4)
Internal comparables (11)
Internal data (5)
Internal group bargaining (1)
Internal set-offs (8)
Interpretation (1)
Interpretation of “deemed” (1)
Interpretation of article 7 (1)
Interpretation of international treaties (1)
Interpreting (12)
Interquartile range (17)
Interrelated transactions (1)
Intra-group loans (60)
Intra-group services (93)
Invalid on formal grounds (1)
Inventories criteria (1)
Inventory (1)
Inventory risk (1)
Investment advisory agreement (1)
Investment fund (1)
Investments made in relation to contractual arrangements (1)
Invoicing center (1)
Ip box (1)
Ireland (4)
Israel (2)
Issued at the same time (1)
IT support services (1)

J

Jersey (1)
Job retention programmes (1)
Joint activities (2)
Joint audit (1)
Joint venture (4)
JTPF profit split report (1)
Juridical double taxation (1)

K

Key contributions to value (1)
Key Entrepreneurial Risk-Taking Function (KERT) (1)
Key is to compare like with like (3)
Key source of economic benefits (1)
Know-how (18)

L

M

M&A (1)
Malta (1)
Management (2)
Management fee (8)
Management of functions (1)
management of group finances (12)
Management services (3)
Mandatory questionnaires (1)
Manual on transfer pricing (1)
Manufacturing (4)
Manufacturing processes (1)
MAP – cancel a penalty (1)
Maquiladora Structure (1)
Marginal adjustments (1)
Marked knowledge (1)
Market approach (1)
Market condition (2)
Market differences (1)
Marketing (6)
Marketing and distribution of goods (2)
Marketing and promotion (2)
Marketing arrangement (1)
Marketing expenditures (1)
Marketing expenses (2)
Marketing hubs (6)
Marketing intangibles (8)
Marketing operations (1)
Marketing services (2)
Market penetration schemes (4)
Market penetration strategy (1)
Market price of shares (3)
Market specific characteristics (1)
Market value of contributions (1)
Master file (6)
Material changes in economic conditions (1)
Material differences (1)
Material differences in functions (2)
Materiality (3)
Materially affect the cost plus mark up (1)
Maturity (3)
Maximum price acceptable to the transferee (1)
Mean (1)
Mean Weighted averages (1)
Measured consistently (1)
Measured in a reliable manner (1)
Measures of profit (2)
Median (8)
Memoranda of Understanding (MOU) (1)
Merger (1)
Merger or acquisition (1)
Methods – strength and weaknesses (16)
Migration of risk (5)
Minimum price acceptable to the transferor (1)
Mining (4)
Mining Industry (2)
Minor product differences (3)
Mismatch (1)
Misrepresentation (1)
MNE group policies (1)
Model tax convention (1)
Modification to contractual arrangements (4)
Modified cost plus/resale price methods (1)
Money laundering (2)
More efficient in manufacturing processes (1)
More parties assuming risk (1)
More than one party exercising control over risk (3)
More valuable in combination with other intangibles (2)
Most appropriate method (1)
Most appropriate net profit indicator (4)
Most appropriate transfer pricing method (45)
Most reliable data (1)
MTC Article 13(4) (1)
MTC Commentaries (1)
Multi-country analysis (1)
Multi-factor analysis (1)
Multible year data (5)
Multilateral Instrument (1)
Multiple-country comparability analysis (2)
Multiple deviations (3)
Multiple methods (1)
Multiple year data (9)
Mutual agreement procedure (MAP) (53)

N

Negligence (1)
negotiates on behalf of group (1)
Negotiating group wide discount (1)
Netherlands (19)
Net profit divided by sales (1)
Net Profit Indicator/Profit Level Indicator (PLI) (37)
Net profit vs gross profit analysis (2)
Net result of funding transactions (1)
Netting transactions (4)
Nexus (1)
No-fault penalty (3)
No activities (1)
No commercial purpose or rationale (2)
No contract (1)
No control over risk (8)
No functions (1)
No local comparables (2)
Non-arm’s-length terms (1)
Non-cash benefits (1)
Non-compete clause in employment contracts (1)
Non-compliance with terms and conditions of an existing APA (1)
Non-Cooperative Tax Jurisdictions (1)
Non-interest bearing (1)
Non-recognition (2)
Non-recognition and re-characterisation (40)
Non-recurring costs (1)
Non-renewal of an existing arrangement (1)
No price acceptable to both parties (1)
No reliable comparables information (1)
No renewal of agreement (1)
No risk (1)
Normal prise (1)
Normal value (3)
No simple solution (1)
No substance (2)
Not-identified transactions (2)
Not a genuine contract (2)
Not an exact science (1)
Notching (1)
Notification of tax administrations (1)
Notional cash pooling (3)
Notional income (1)
Notional interest (1)
Not LVAS (2)
Not tolerate losses that continue indefinitely (1)
No written terms (5)

O

P

Package deal (3)
Parent company guarantee (2)
Participation in a CCA (1)
Participation loan (1)
Participation requirements CCA (1)
Passing on benefits to customers (1)
Passing on costs to customers (1)
Passing on government assistance (4)
Passive association (3)
Pass through contract (1)
Pass through costs (5)
Pass through loans (1)
Patent (2)
Patent administration service (3)
Patents (8)
Payment for manufacturing contract (1)
Payment of indemnification (3)
PDCF (1)
Penalties (1)
Penalty (21)
Penalty for tax understatement (1)
Penalty vs interest vs additional tax (1)
Performed all critical functions (1)
Periodic reassessment (1)
Permanent establishment (30)
Perspective of both parties (5)
Pharma (1)
Pharmaceutical (13)
Pharmaceutical products (1)
Physical pooling (1)
Piaggio (1)
Pillar I (1)
Pillar II (1)
Pipeline (1)
Platform for Collaboration on Tax (1)
Platform rights (2)
Platts quotes (2)
POEM (1)
Pool of cost (7)
portfolio approach (1)
Portfolio approaches (2)
Portfolio management (1)
Post Restructuring Remuneration (19)
Post restructuring results (1)
Potassium chloride (1)
Practical approaches (7)
Pre- and Post Restructuring Result (9)
Pre-existing contributions (2)
Pre-existing intangibles (8)
Pre-restructuring and post-restructuring scenarios (1)
Pre-tax basis (2)
Precise timing of the transaction (1)
Precision of budgets (3)
Prefered methods (1)
Preferential tax regimes (2)
Premium over trading value (1)
Prescriptive list of criteria (1)
Prescriptive list of profit splitting factors (1)
Presence of minority shareholders (1)
Preserve profitability (1)
Preventing determination of a price (1)
Prevent profit shifting (1)
Price-setting policy (1)
Price adjustment (2)
Price adjustment clause (3)
Price adjustment mechanisms (1)
Price controls (2)
Price formula (1)
Price setting (1)
Price sharing (1)
Pricing captive insurance (11)
Pricing cash pool transactions (21)
Pricing controlled transactions involving intangibles (1)
Pricing date (1)
Pricing does not determine risk assumption (1)
Pricing formulas (1)
Pricing guarantees (14)
Pricing intangible transaction (13)
Pricing of premiums (3)
Pricing the transaction (7)
Prima facie loan (2)
Principle of proportionality (1)
Printers and cartridges (1)
Procedural compliance (1)
Procurement (20)
Product complementarities (1)
Product improvements (1)
Product life cycles (3)
Profit (and losses) (1)
Profit adjustment (1)
Profit Level Indicator (PLI) (1)
Profit potential (5)
Profits = Profit or Loss (1)
Profits aligned with contributions (1)
Profit sharing (1)
Profit split (2)
Profit split examples (7)
Profit split for intangibles (1)
Profit split indicators (5)
Profit split method (105)
Profit splitting factors (19)
Projected shares of benefits (1)
Proprietary databases (1)
Protection (2)
Provision of services (1)
Prudent and diligent business manager (3)
Prudent business management (1)
Publicly available information (1)
Purchase Price Allocation (PPA) (3)
Purchase price premium (1)
Purchase volumes (3)
Purchasing power (9)
Purported loan (1)
Purported transfer of risk (1)

Q

Qualified cost-sharing arrangements (2)
Qualifying enterprises (1)
Qualifying transactions (1)
Quantitative and qualitative criteria (2)
Quoted commodity prices (1)
Quoted price (3)

R

R&D (3)
R&D payments (1)
R&D services (1)
Range of results (1)
Rarely used among independent (1)
Ratio analysis (2)
Rational investor (1)
Re-negotiation (1)
Real Estate (1)
Reallocation of profit potential (10)
Reasonable estimate (1)
Reasonably accurate adjustments (3)
Rebates and discounts (1)
Rebuttable presumption (1)
Recharacterise (3)
Recognition of actual transaction (15)
Recognition of all contributions (1)
Recommendation of the OECD Council (1)
Reduction in costs (1)
Refinancing (1)
Refrain form challenging (1)
Regarded as a loan for tax purposes (1)
Regional HQ (1)
Registration of ownership (6)
Registred owner (3)
Regulatory licence (3)
Reimbursement of cost (1)
Reinsurance (2)
Rejection of comparables (1)
Related-party loan (2)
Relative contributions of the parties (1)
Relative value of contributions (10)
Relevant costs (4)
Relevant profits (9)
Relevant profits and costs (3)
Relief from double taxation (2)
Relief from Royalty method (4)
Relocation of risk (1)
Remuneration for assets used (1)
Renegotiation of agreement (2)
Renegotiation of contract (4)
Renegotiation of the existing contractual arrangements (8)
Rent (2)
Reorganisation (2)
Repatriation of dividends (1)
Repeated analysis (1)
Replacement of transaction (1)
Replaces the cross-licensing arrangements (1)
Replicate arm’s length behaviour (1)
Resale price margin (1)
Resale price method (4)
Resale price method (RPM) (30)
Research and development (3)
Research and development costs (1)
Research and development expenses (1)
Reseller adds no substantial value to the product (1)
Reseller contributes to intangibles (1)
Reservation price (3)
Residual-business assets (1)
Residual analysis (4)
Residual profit split (3)
Restructuring of legitimate business transactions (1)
Restructuring of transactions (1)
Results attributable to commercial factors (1)
Retention of documents (2)
Retroactive indebtedness (1)
Retrospective documentation (1)
Return on assets or return on capital employed (1)
Reversed burden of proof (1)
Review of the controlled transaction (1)
Revised tax return (1)
Revision of APA (3)
Revocation of APA (1)
Rights of dividends (1)
Rights to enhancements/development (1)
Rigid standard of comparability (1)
Risk (1)
Risk-adjusted rate of return (12)
Risk-free rate of return (12)
Risk actually assumed (6)
Risk analysis (6)
Risk analysis – 6 step (37)
Risk assessment (14)
Risk assumption (62)
Risk control functions (2)
Risk deversification (7)
Risk free return (3)
Risk incurred (1)
Risk Management (4)
Risk mitigation (7)
Risk premium (2)
Risk return trade off (5)
Round robin (3)
Roundtrip arrangement (2)
Routine distributor (2)
Royalties (2)
Royalty (2)
Royalty and License payments (56)
Royalty barrier (1)
Royalty routing (2)
Rule of 183 days (1)
Rule of thumb (1)
Russia (1)

S

Sacrifice of profit potential (1)
Safe habor rates (1)
Safe harbor (40)
Sale-and-lease-back (4)
Sale-and-lease-back considered a loan (2)
Sale of property (1)
Sale of subsidiary (1)
Sale of the trademark (1)
Sales and distribution (1)
Sales and marketing hubs (18)
Sales commissions (1)
Sales services (1)
Sales tax (1)
Sales through Singapore (2)
Samoa (1)
Sanity check (1)
Saved from anticipated losses (1)
Scam (2)
Schedule of repayment (1)
Search criteria (7)
Secondary adjustments (2)
Secret comparables (7)
Segmentation of financial data (1)
Segmented financials (1)
Segregated financial data (3)
Segregated transactions (1)
Selective advantage (1)
Selectivity (1)
Self-developed intangibles (4)
Self incrimination (1)
Semi finished goods (1)
Senate hearing (1)
Seniority (1)
Separately assumed risk (1)
Separate rights in intangibles (1)
Separate testing periods (2)
Separate transfer of goodwill (1)
Separation of ownership and DEMPE (2)
Seperate entity (5)
Series of related transactions (6)
Service cost (2)
Service examples (3)
Service fee (87)
Service fees (1)
Service provider to CCA (1)
Services (71)
Services CCAs (2)
Services performed for legal owner of the trademark (1)
Set of comparables (3)
Settlement (1)
Sham transactions (5)
Share capital (1)
Shared assumption of risk (13)
Shared service center (4)
Shareholder (1)
Shareholder activity (3)
Shareholder interests (1)
Shareholder loan (1)
Shareholder services (1)
Shares (1)
Share the upside and downside consequences of risks (1)
Shell (3)
Shifting burden of proof (1)
Shifting of risk (1)
Shipment date (1)
Short- term liquidity management arrangement (1)
Short-term loan to manage long term need (1)
SICAV (1)
Significant people function (2)
Simplification of multiple transactions (1)
Simplified approach (2)
Simplified approach not adopted (1)
Simulated transactions (1)
Simultaneous tax examinition/audit (16)
Singapore trading hub (2)
single unified economic entity (1)
Sixth method (1)
Size criteria (1)
Size of gross margin (2)
Small to medium sized enterprises (1)
Soft spots (1)
Software (1)
Sophisticated adjustments (1)
Source code (1)
Sources of risk (1)
Sourcing services (1)
Specific – unique – facts and circumstances (1)
Specific characteristics of CCAs warrant special consideration (1)
Split of actual or anticipated profit (4)
Split of actual profits (5)
Split of anticipated profits (5)
Splitting gross profits (3)
Splitting operating profits (1)
Standing in the shoes of (1)
Starbucks (1)
Start-up companies (2)
Start-up loss (4)
Starting point (2)
State aid (4)
Stateless income (1)
Stateless revenue (1)
Statistical tools (4)
Statuatory powers (1)
Statutes of limitation (3)
Statutory powers (1)
Step-up clause (1)
Stewardship activities (2)
Stipulation of settled Issues (1)
Stock-based compensation/Stock options (5)
Strategic risks or marketplace risks (3)
Strategic significance (1)
Streamlined system of netted payments (1)
Strengths and weaknesses (1)
Structural advantage (1)
Structured finance transactions (2)
Structure of the arrangement (1)
Subject to industry regulations (1)
Submission of evidence (3)
Subordination (1)
Substance over form (29)
Substance test (2)
Substantial commercial activity (1)
Substantial part of anticipated returns (1)
Successful business acquired (1)
Sufficiently comparable (1)
Sufficiently reliable comparables (2)
Supply chain (2)
Supporting documentation (1)
Supportive nature (1)
Support services (7)
Swap (3)
Swiss trading hub (8)
Switzerland (21)
Synergies (6)
Synergistic benefit (1)
Synthetic transfer (1)
System profit (1)

T

TAB (1)
tainted sales income (1)
Taking over loss-making activity (2)
Tax advantages (4)
Tax advisor liability (2)
Tax arbitrage (1)
Tax assessment (2)
Taxation of balancing payments (3)
Taxation of contributions (1)
Tax avoidance (33)
Tax avoidance arrangements (4)
Tax benefits (1)
Tax competition (1)
Tax compliance (2)
Tax consideration (1)
Tax depreciation (3)
Tax effects (1)
Tax evasion (6)
Tax fraud (1)
Tax free dividends (1)
Tax havens (4)
Taxing rights (1)
Tax losses (2)
Taxpayers circumstances (1)
Tax planning (3)
Tax reduction request (1)
Tax risk indicators (1)
Tax ruling (3)
Tax rulings (2)
Tax schemes (14)
Tax structure (1)
Tax treatment (1)
Technology license agreements (2)
Teleworking costs (1)
Termination (26)
Termination clause (3)
Termination costs (1)
Termination fee (1)
Termination of contract (1)
Termination of employment contracts (1)
Termination of operations (3)
Termination of option (1)
Terms and conditions (3)
Terms of delivery (1)
Terms of transportation (1)
Tested party (18)
Thin cap (7)
Three tiered approach (2)
Threshold for LVAS (1)
Time between purchase and selling (1)
Time frame documentation (3)
Time spend (2)
Timing issues (15)
Timing of adjustment (2)
Timing of expenditure (2)
TNMM (8)
Toll manufacturer (2)
Toolkit (1)
Total return swap (1)
TPG version (1)
Trademark (20)
Trademark license agreement (3)
Trade name (4)
Trade names (4)
Trade secrets (1)
Trading companies (1)
Trading hub (4)
Traditional transaction methods (50)
Traditional transaction methods preferred (1)
Transactional differences (1)
Transactional net margin method (TNMM) (85)
Transactional profit methods (47)
Transactional profit split method (1)
Transactional risks (1)
Transactions involving the use of intangibles (2)
Transactions involving transfers of intangibles (1)
Transactions not seen between independent (1)
Transactions that are economically inter-related (1)
Transfer of activity (2)
Transfer of FAR (1)
Transfer of fully developed intangibles (1)
Transfer of individual employees (1)
Transfer of intangibles (9)
Transfer of intangibles in combination with tangible assets (1)
Transfer of inventory (2)
Transfer of know-how (1)
Transfer of ongoing concern (3)
Transfer of profits abroad (3)
Transfer of rights in intangibles (1)
Transfer of risk (2)
Transfer of something of value (1)
Transfer of tangible assets (1)
Transfer of value (27)
transfer or secondment of one or more employees (1)
Transfer pricing (3)
Transfer pricing audit (2)
Transfer pricing disputes (1)
Transfer pricing documentation (97)
Transfer pricing forms (1)
Transfer Pricing Guidelines (7)
Transfer pricing legislation (1)
Transfer pricing methods (245)
Transfer pricing methods for intangibles (15)
Transfers of combinations of intangibles (1)
Transfers of intangibles (1)
Transfers of partially developed intangibles (1)
Transparency (5)
Transparent systematic and verifiable (3)
Treasury (2)
Treasury functions (151)
Treasury regulations (1)
Treaty (1)
Treaty Abuse (2)
Treaty benefits (1)
Treaty shopping (3)
Trible dip (1)
Triple dip (1)
Two-sided analysis (3)
Two-sided method (3)
Two step process (1)
Types of risk related to intangibles (2)

U

UK parliament (1)
UK treasury company (1)
Unable to pay interest on loan (2)
Unconstitutional (2)
Uncontrolled arrangements claimed to be comparable (1)
Underlying contractual obligations (1)
Under taxing (1)
Underwriting function (1)
Unforeseen developments (1)
UN Guidelines (1)
Unified Approach (1)
Unintentional over-reporting of taxable income (1)
Unique and valuable contributions (25)
Unique and valuable contributions by each party (1)
Unique and valuable intangibles (5)
Universal formula (1)
Unjustified tax benefit (9)
UN manual (1)
Unpredictable events (2)
Unrecognized transaction (1)
Unrelated party (1)
Unsecured loans (2)
Unusual expenses (1)
Up-front compensation vs future lower prices (2)
Update every year (1)
Uranium (1)
Useful information (4)
Useful life (1)
Use of Assets (5)
Use of average costs (1)
Use of company name (5)
Use of credit ratings (14)
Use of goodwill (1)
Use of intangibles (3)
Use of more splitting factors (2)
Use of more than one method (5)
Use of non-transactional third party data (1)
Use of non-unique intangibles (4)
Use of other methods (3)
Use of range (1)
Use of trademark (1)
Use same method as taxpayer (2)
US Supreme Court (1)
US Treasury (1)

V

Valuable functions (1)
Valuable intangibles (1)
Valuation (72)
Valuation of inventories (1)
Valuation of loss-making activity (1)
Valuation on aggregate basis (3)
Valuation techniques (34)
Value (1)
Value at the time they are contributed (1)
Value based splitting factor (1)
Value chain (1)
Value chain analysis (1)
Value does not disappear (2)
Value highly uncertain (1)
Value of contract (1)
Value of contributions (13)
Value of each participant’s contribution (2)
Variations in operating expenses (1)
VAT (Costoms) (1)
VAT fraud (2)
Verifiable data (1)
Vespa (1)
vGA (verdeckte Gewinnausschüttung) (4)
Violation of the treaty (1)
Vital components (1)
Volume discounts (3)

W

WACC (1)
WARA (1)
Warranty (3)
Weighted averages (2)
Which of the associated enterprises’ profits should be reduced (1)
Whirlpool (1)
Wider policy-setting (1)
Wilful intent to evade tax (2)
Withholding tax (8)
Withholding tax only on profits (1)
Workforce in place (4)
Working capital adjustment (2)
World trade (2)
Write off (1)
Written Agreement/Contract (16)

Y

Year-end adjustments (1)
Year end adjustment (3)
Yield approach (4)

Z

Zero-coupon (2)
Zero balancing pool (2)

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