Description
This template is a draft contract construed on the idea of the so-called “target margin model” for product or service transactions using the TNMM system as the OECD arm’s length approach.
The TNMM arm’s length model deems one transaction partner the “routine unit”.
The template provides for the relevant text bodies to implement such related-party contract into the transfer pricing system.
The articles of the GTP® MALL provide for standardized data, structures, analysis results, and templates (hereinafter called “Deliverables”). With means of further processing, customizing, modifying, such deliverables can be deployed by the transfer pricing manager of multinational groups, regardless of inhouse experts or external experts.
Such standardized deliverables shall not be deemed tax consulting services, legal services, or audit services in the meaning of the professional legal code of the respective country.
Deliverables of the online shop (GTP® MALL) will have to be customized and added with case-specific data – in particular in the case of document templates. In particular, contract templates are of a generalized nature. The customer and its users of such deliverables are requested to individualize the template on a case-by-case basis. Neither any factual nor any legal assessment of the individual case is the content and deliverable of the products delivered by using the GTP® MALL.
We strongly recommend the customers and user of the deliverables to involve an authorized tax consultant, legal advisor, and/or auditor (public certified accountant) to review the deliverables of the GTP® MALL and to consent as to whether the articles of the GTP® MALL might have a legal or tax impact.
