Commodity Traders: Transfer Pricing in the Era of Tax Transparency

Given the scale and profitability of firms operating in commodity trading industry, and with the rapidly progressing changes in the tax and transfer pricing landscape, it is expected that commodity traders will be under increasing pressure to review their approach to transfer pricing. In this article, the authors aim to examine the most critical aspects relevant for such review, with a particular focus on a role and contribution of each part of the trading business and the degree of risk taken by (part of) enterprise.