In a third-party scenario, most entities that are part of a multinational enterprise group would operate as manufacturers or distributors or service providers or a combination. These entities would generally be characterized as cost-plus entities or limited risk entities or risk-taking entrepreneurs etc.
Due to their diverse functional characterizations, there are several key Transfer Pricing implications and challenges associated with each of these entities.
Kindly participate in the forthcoming Breakfast Talk organized by ISCA.
Sahil SethDirector – Transfer Pricing
PKF-CAP LLP, Singapore
Sahil is a Transfer Pricing specialist with over 17 years of experience across Big 4 firms and reputed mid-tier firms. He advises clients on Transfer Pricing compliance, planning, advisory and dispute prevention & resolution matters, helping businesses develop robust intercompany pricing policies, reviewing transactions and business models, highlighting potential red flags, and conducting economic analyses for transactions such as services, manufacturing, distribution, loans, IP related arrangements, complex financial transactions etc. He has extensive experience with all OECD BEPS 1.0 and 2.0 programs, APAs, Permanent Establishment related issues, Value Chain Alignment analysis etc, while serving clients across a wide range of industries.