- 8 Marks
AT – Nov 2019 – L3 – Q3b – International Taxation
Recommend and justify the most suitable transfer pricing method for Pyrotechnics Ghana Limited.
Question
Pyrotechnics Ghana Limited was established for the main purpose of providing marketing support services to Pyrotechnics UK Limited, its parent company. Pyrotechnics Ghana Limited’s expenses are reimbursed with a 5% mark-up, which constitutes its total revenue.
Required:
What is the best transfer pricing method that can be used to test this transaction? Justify your response and show how the method will be applied.
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