Derren JosephDerren is a part of an international tax team that works with 6, 7 and 8 figure International Entrepreneurs, Expats and Investors to legally minimize their global tax burden and protect their wealth. Strategies include second citizenships, second residencies, trusts, foundations, insurance wrappers and other offshore structures.
Transfer Pricing Strategy – Limited vs. Full Risk Distributor
We’ve written about TP before – https://htj.tax/?s=transfer+pricing
Today we get into strategy a bit more as opposed to just policy documents.
General issues to be kept in mind while structuring a global transfer pricing policy:
Distribution activity
Limited risk distributors are a relatively common feature of intercompany arrangements within multinational groups. The essence of the arrangement is of course to de-risk the role of the intra-group distributor, resulting in a correspondingly lower return or margin for the distributor. In many ways, the position of the distributor is commercially analogous with that of a commercial agent or commissionaire.
What to know
Chances are you need to have a lawyer draft an appropriate distribution agreement once you decide on distribution strategy.
What to do
Table of Contents: Transfer Pricing Strategy – Limited vs. Full Risk Distributor
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