In their article for a leading German publication, Transfer Pricing International, NERA Managing Director Dr. Yves Hervé and former Consultant Georg Siegert analyze the OECD’s revised guidance on the application of the transactional profit split method.

The authors make the point that, when comparable transactions are unavailable, it is often the presence of unique and valuable contributions, the high integration of business operations, or the assumption of economically significant risks that determine whether a transactional profit split method should be applied.

The January 2019 edition of TPI can be purchased here.