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Addressing Location-Specific Advantages in Asia Pacific: Increasing Application of the Profit Split Method

Deloitte Dbriefs | Transfer Pricing

Start date and time

August 13, 2014 2:00 PM

End date and time

August 13, 2014 3:00 PM

Time zone:

(GMT-05:00) Eastern Time (US & Canada)

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Host: Mark Nehoray, Partner - Deloitte Tax LLP
1 Intermediate CPE Credit: Taxes 

With location-specific advantages (LSAs) dominating transfer pricing in India and China, how should multinationals determine additional profit sharing from global value chains attributable to LSAs? Could LSAs assume relevance in other Asia Pacific countries? We'll discuss:

  • Importance of geographic market factors potentially leading to LSAs, including possible location savings, market premiums, and group synergies.
  • Recent developments on the interpretation and quantification of LSAs in transfer pricing – could an item-by-item calculation or residual profit split approach be possible ways?
  • Adapting transfer pricing analysis and documentation to address the inherent complexity of LSAs.

Gain new insights on LSAs and ways to prepare for potential tax authority review.

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