International - Supply Chain Management Using Alternative Manufacturing Models
- S. Kishore Bilaney
- International Transfer Pricing Journal, 2014 (Volume 21), No 2
- 12 March 2014
The author considers various manufacturing models (such as full-fledged manufacturer; licensed manufacturer; and contract or toll manufacturer); function, asset and risk analysis under each model; arm’s length remuneration under each model; conversions of manufacturing models and related issues; the OECD response to base erosion and profit shifting; exposure to location savings and permanent establishment risk under various models.