International - Impact of BEPS Project on Centralized Operating Models
- S.K. Bilaney
- International Transfer Pricing Journal, 2017 (Volume 24), No 2
- 22 February 2017
The central operating models adopted by MNEs for marketing & distribution and for procurement of commodity products may be challenged by the tax authorities in light of the BEPS Final Report. The author considers plausible transfer pricing challenges, and offers solutions that may mitigate transfer pricing risk for MNEs having central operating models.