Transfer Pricing
1. Aufl. 2021
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2. The first step: Value Chain Analysis (Christian Schwarz and Stefan Stein)
2.1. Value Chain Analysis
Basic Problem. A good and substantiated understanding of value creation in an MNE group is the initial starting point for transfer pricing analysis. This principle is internationally recognized and formulated in Section 1.51 of the TPG as follows:
„In particular, it is important to understand how value is generated by the group as a whole, the interdependencies of the functions performed by the associated enterprises with the rest of the group, and the contribution that the associated enterprises make to that value creation.”
The idea is that the determination of transfer prices is based on economic reality, i. e. the contributions of the individual entities belonging to an MNE group, which is reflected in the added value. The determination of value creation within an MNE group can be based on business methods and concepts, for example by means of an analysis of value chains, business model analysis or the examination of responsibilities within business processes.
Where can it be found. Chapter I of the TPG contains explanations of the function and risk analysis as well as a value-dri...