Business models of MNEs change over time. With them, intercompany transaction flows take different shapes and pricing for these transactions has to keep pace. The challenge now is to accommodate the globally integrated, network-oriented business models that are commonplace. ACL has extensive experience designing transfer pricing systems and policies that facilitate the successful implementation of new business models and satisfy the arm’s length principle. This requires looking beyond simple functional profiles to how entrepreneurial responsibilities dispersed throughout the MNEs are involved in the joint creation of value and intangibles.
The current highly dynamic and unpredictable business environment
Multinational businesses are increasingly affected by tax, legislative and regulatory
We can help you embed your transfer pricing policy within your wider business strategy