Download or read book Practical Application of the Profit Split Method written by and published by . This book was released on 2015 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: QUESTIONS: 1. Please indicate if the profit split method is provided for in your country legislation and, if so whether your country legislation provides guidance on its application. Please elaborate on the domestic guidance on this issue which goes beyond the guidance contained in Chapter II of the OECD Transfer Pricing Guidelines. In case your country legislation does not provide for the use of the profit split method, please explain whether it is actually used in practice by taxpayers and its acceptability by tax administrations. 2. Based on your practical experience, please elaborate in what scenarios/structures/circumstances is the profit split method found to be the most appropriate method. Please also provide information on which are the instances in which profit split method is most commonly used (e.g. application by taxpayer, audit, APA, dispute resolution). 3. Based on your practical experience, what information can be useful in determining the arm's length allocation among the entities of a group of the (residual) profit under the profit split method (e.g. information prepared for tax and non-tax purposes; information from third party cooperative arrangement, such as joint ventures), and what are the practical obstacles to obtain and/or use such information in the transfer pricing analysis. 4. Based on your practical experience, please indicate which are the key limitations and/or practical difficulties encountered in applying the profit split method (e.g. new business models/operating structures, access to information, computation of profits, identification of appropriate allocation keys), and how could these be overcome or minimized.