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October 06, 2009
In general, extensive documentation has to be prepared to demonstrate the application of the benefit test. Will the EU Joint Transfer Pricing Forum provide guidance for simplifications?
Preparation of transfer pricing documentation as a compliance issue can become quite extensive in the case of administrative services as the elimination of shareholder costs, demonstration of the benefit and the arm's-length character of the cost basis and allocation keys are a challenge for each multinational enterprise.
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