Transcription of Chapter 5 Transfer Pricing Methods - United Nations
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Chapter 5 Transfer Pricing Methods - United Nations
Agenda Item 5 Working Draft Chapter 5 Transfer Pricing Methods [This paper is based on a paper prepared by Members of the UN Tax Committee s Subcommittee on Practical Transfer Pricing Issues, but includes some Secretariat drafting and suggestions not yet considered by them the Secretariat takes responsibility for any relevant errors and omissions. Formerly, Methods were dealt with in Chapters 4 and 5, which are now combined hence the reference, on a temporary basis, to Parts 5A and 5B of this paper]. [Table of Contents to be added] Chapter 5A Traditional Methods 1.
Page 4 of 65 Assets used or contributed: the functional analysis must identify and distinguish tangible assets and intangible assets. Tangible assets such as a property, plant and equipment have to
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