Central Procurement Operating Models in a Multinational Group

This article analyses the transfer pricing considerations in relation to a central procurement operating model, in line with the OECD Transfer Pricing Guidelines (2017) and the recommendations from the OECD’s Base Erosion and Profit Shifting (BEPS) Project. The analysis also addresses the arm’s length approach to allocate joint efficiencies within a multinational group. It furthermore takes into account the specific court cases and subsequent transfer pricing decrees in the Netherlands related to these central procurement structures.