Form C YA 2022 – Characterisation of Entities for Transfer Pricing Purposes: Distribution Activities
Functional Analysis (“FAR”) The necessity to carry out a Functional Analysis, which determines whether controlled and uncontrolled transactions are equivalent, is an essential part of the Arm’s Length Principle. This functional analysis aims to identify and compare the economically relevant activities and responsibilities (i.e. Functions) that were carried out by the parties to the transaction, […]
