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Muhammad Imran Transfer Pricing Skill Set
Muhammad Imran Transfer Pricing Skill Set
Step 1:
Transfer of Transfer of
Transfer of Transfer of Intra Intra-Group
Tangible Capital Tangible
Intangible Assets Group Services Loans
Assets Products
Transaction Analysis
Functional Analysis
Risk Analysis
Experienced in analyzing
Academic Study
1. Transfer Pricing and Corporate
Taxation (King, Elizabeth)
2. Transfer Pricing and Corporate
Income Taxation (Lorraine Eden)
3. Transfer Pricing of Intangible Property
(Susan C. Borkowski)
4. Transfer Pricing in Canada (Francois
Vincent, currently studying)
Main Methods
Covered
Economics Analysis
Identify Comparibility
Determine Comparables
Measures
Contemporaneous Documentation
Documentation to present the arm's-length
character of the transaction