o Marketing of intangible assets such as brand names, customer lists, brands, etc., can be transferred to the client The type of intercompany transactions in the manufacturing sector is changing as SMEs adapt to the transformation of the sector through renewed business models and structures to achieve operational efficiency and agility to cope with changes , as well as better access to growing demand. At the same time, traditional transfer pricing issues in manufacturing remain important in addressing the risks associated with pricing transfers. These traditional themes include: SMEs in the manufacturing sector should continue to address the risks associated with uncertainty related to factors such as material prices, government regulations, the political climate, exchange rate fluctuations and consumer demand. In addition, the rapid growth of global markets, technological advances and the consequences of the Great Recession from 2007 to 2009 face many transfer pricing challenges, some of which relate to traditional topics that continue to be discussed in the tax and business world, while others are relatively new topics that increase the level of uncertainty in transfer pricing and corporate governance. and may require a new look at traditional approaches to transfer pricing. A licensed manufacturer produces products under a licensing agreement using the licensee`s intangible products, such as patents, product design, manufacturing processes and know-how. The licensed producer pays royalties for the use of licensed intangibles, generally buys raw materials and semi-products on his own behalf, and stores raw materials and finished products. It therefore bears the risks associated with stock retention and the sale of products, including the risks associated with demand and prices. The licensed manufacturer generally has the facilities and equipment necessary for the production of labour and invests in the training of its workforce. The manufacturer also supplies the equipment, machinery and manpower needed to manufacture the product in question, but also supplies and supplies the necessary raw materials. This means that the manufacturer bears the associated risks, such as costs, inventory levels and quality control of the raw materials to be used – although the allocation of these risks can of course be contractually adjusted by price provisions, guarantees and compensations.
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