The parties to the transaction share significant economic risks or each party bears closely related risks separately.there is an interconnection of the functions, risks and assets used undertaken by the parties to the transaction, so that the contribution of each party cannot be reliably measured separately The business operations are highly integrated, i.e.Each party to the transaction makes a unique and valuable contribution (a unique and valuable contribution includes not only the assets used, such as intangible assets, but also the functions performed).OECD recognizes that the PSM should be considered as an appropriate Transfer Pricing method in the following scenarios: The new Transfer Pricing Guidelines clarify and expand on when the PSM may be the most appropriate Transfer Pricing method, as well as to provide further cases for reference by tax authorities and enterprises when applying the PSM. The application of Profit Split Method (PSM)

Transfer pricing guidance on financial transactions.Guidance on the application of the approach to Hard-to-Value Intangibles.The revised guidance on the application of the transactional profit split method.

The new TP Guidelines has mainly combined the following aspects which has been published by OECD in the BEPS framework in the past couple of years: On 20 January 2022, the OECD released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Insights OECD Released New Transfer Pricing Guidelines

Rödl & Partner World Market Leader Index Germany.

Transfer pricing oecd