Safe harbour transfer pricing revised to define employee cost and include low value-adding intra-group services with certification requirements. Amendments refine the transfer pricing safe harbour framework by redefining accountant for certification, codifying an inclusive employee cost definition with an eighty percent deeming rule for unascertainable outsourcing employee cost, and introducing low value-adding intra-group services with functional criteria and specified exclusions. The rules set operating margin and employee-cost thresholds for specified services, prescribe interest and commission floors for intra-group loans and guarantees linked to reference rates and credit ratings, and require accountant certification of cost pooling and allocation for low value-adding services.
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Safe harbour transfer pricing revised to define employee cost and include low value-adding intra-group services with certification requirements.
Amendments refine the transfer pricing safe harbour framework by redefining accountant for certification, codifying an inclusive employee cost definition with an eighty percent deeming rule for unascertainable outsourcing employee cost, and introducing low value-adding intra-group services with functional criteria and specified exclusions. The rules set operating margin and employee-cost thresholds for specified services, prescribe interest and commission floors for intra-group loans and guarantees linked to reference rates and credit ratings, and require accountant certification of cost pooling and allocation for low value-adding services.
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