European Tax Summit 2008
Montreux, Switzerland
10 February 2008- 12 February 2008
Hosted By: marcus evans
In light of recent case law, new domestic regulations on business migration, and current OECD discussions on business transformation and conversion, NERA Special Consultant Pim Fris and Associate Director Jean-Sébastien Lénik delivered a presentation on "Valuation and Profit Split Analyses: Reconciling the Outside and Inside Valuation Challenge" at this marcus evans tax summit in Montreux on 11 February 2008.
Mr. Fris and Mr. Lénik discussed the importance of the link between the inside valuation paradigm driven by transfer pricing rules and valuation between unrelated parties driven, in most cases, by discounted cash flows approaches, comparable transaction inference techniques and option pricing models. Using the Ford Motor Company case law, emphasis was placed on the importance of the use of value chain and sound contribution analyses in connection with economic and financial valuation techniques to address today's MNEs outside and inside valuation challenge.
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