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4.3.2.1. Modified Residual Profit Split Method
The OECD’s first proposed method, the so-called Modified Residual Profit Split Method…
1. First, the total profit of MNE to be split needs to be determined,…
2. As a second step, the routine profits need to be removed from the total profit…
3. The non-routine profit or residual profit would arise as a result of the second…
4. Lastly, the non-routine profit would be allocated to the relevant market jurisdictions…
It is understood from the May PoW that options and issues relating to the MRPS method…
4.3.2. The OECD’s Proposals under the May Programme of Work
4.3.2.2. Fractional Apportionment