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Practical Guide to U.S. Transfer Pricing, Third Edition

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ISBN: 9780820569499
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Transfer pricing is one of the hottest topics in international tax today. Transfer pricing rules are an inescapable part of doing business internationally, and this third edition of Practical Guide to U.S. Transfer Pricing provides an in-depth analysis of the U.S. rules. This product is designed to help multinationals cope with the U.S. transfer pricing rules and procedures, taking into account the international norms established by the Organisation for Economic Co-operation and Development (OECD). It is also designed for use by tax administrators, both those belonging to the U.S. Internal Revenue Service and those belonging to the tax administrations of other countries, and tax professionals in and out of government, corporate executives, and their non-tax advisors, both American and foreign.

The U.S. rules are presented along with ideas on how to apply them in a common-sense fashion in a multi-jurisdictional world. A few of the highlights in the latest update to the treatise are as follows:

  • The most important development in transfer pricing ending July 2015 has been the momentum of the OECD's Base Erosion and Profit Shifting (''BEPS'') initiatives, and their forthcoming impact on the European Union, United Nations, and domestic transfer pricing policies. Of particular impact are the OECD initiatives regarding documentation and reporting, relation to risks and capital, and intangibles.
  • In December 2015, the OECD still plans to deliver a discussion draft on changes to the transfer pricing rules to limit base erosion via interest deductions and other financial payments. Of the OECD 2015 developments, the most impactful is the Country-by-Country Reporting. The OECD BEPS country-by-country reporting initiative is receiving, in particular among developing countries, widespread interest and adoption for 2016 by many countries.
  • In new chapter ''Application of the Comparable Profit Split Method (CPSM) to Business Service Providers,'' we examine compensation data from a recent study to discuss how the CPSM may be applied in practice. Business service companies, especially professional, scientific, and technical service providers, can readily produce compensation data from existing accounting systems and such data can be a reliable proxy to define economic ownership of intercompany profits.
  • Authors / Contributors

    Table of Contents

    CHAPTER 1: Overview of Transfer Pricing

    CHAPTER 2: Framework for U.S. Transfer Pricing Analysis Under Treasury Regulation Section 1.482-1 -- OECD Guidelines Compared

    CHAPTER 3: Determination of Related Person Status

    CHAPTER 4: Finding and Selecting Comparables

    CHAPTER 5: Comparable Uncontrolled Price (CUP) Method

    CHAPTER 6: Resale Price Method (RPM) and Alternatives to Traditional Buy-Sell Distributors

    CHAPTER 7: Cost Plus Method

    CHAPTER 8: Transfer Pricing Rules and Methods for Intangible Property

    CHAPTER 9: Comparable Profits Method

    CHAPTER 10: Profit Split Methods

    CHAPTER 11: Unspecified Methods

    CHAPTER 12: Functional Analysis and Choosing the Best Method

    CHAPTER 13: Cost Sharing Arrangements

    CHAPTER 14: Transfer Pricing for Services Under the 1968 and 2009 Treasury Regulations

    CHAPTER 15: Determining Arm's Length Interest and Rent

    CHAPTER 16: Financial Industry Transfer Pricing Issues

    CHAPTER 17: Second-Level Effects of Transfer Pricing Adjustments

    CHAPTER 18: Documented Self-Compliance and Transfer Pricing Penalties

    CHAPTER 19: Advance Pricing Agreements (APAs)

    CHAPTER 20: IRC Sections 6038A and 6038C: Record-Keeping, Record Production, and Reporting for Foreign-Owned Groups

    CHAPTER 21: Examination and Appeals

    CHAPTER 22: Competent Authority to Avoid Double or Excessive Taxation From Transfer Pricing Adjustments

    CHAPTER 23: Transfer Pricing Litigation

    CHAPTER 24: Relationship of Section 482 to Other Code Sections

    CHAPTER 25: Transfer Pricing Effects of Customs Actions and Customs Effects of Transfer Pricing Actions

    CHAPTER 26: State Tax Transfer Pricing Issues

    CHAPTER 27: International Strategy for Transfer Pricing Compliance: A Checklist for Multinationals

    CHAPTER 28: Transfer Pricing Aspects of Business Restructurings -- Chapter IX of the OECD Guidelines

    CHAPTER 29: Application of the Comparable Profit Split Method (CPSM) to Business Service Providers

    APPENDIX A: Table of Transfer Pricing Acronyms and Definitions

    APPENDIX B: Announcement 2015-11, 2015-15 IRB 883

    APPENDIX C: What Every Member of the Trade Community Should Know About: Determining the Acceptability of Transaction Value for Related Party Transactions (An Informed Compliance Publication (April 2007) from U.S. Customs and Border Protection, U.S. Department of Homeland Security)