Practical Guide to U.S. Transfer Pricing
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The new 4th Edition of Practical Guide to U.S. Transfer Pricing continues to be the authoritative legal treatise for tax counsel, tax authorities, the judiciary, and policy makers. The 4th Edition is fully revised with several new chapters, over 2,000 pages of analyses and practice notes, 51 chapters divided over six parts. Part I: U.S. regulatory analysis, application of transfer pricing methods, and jurisprudence; Part II: OECD; Part III: United Nations; Part IV: European Union; Part V: Industry topics; and Part VI: Country practice and tax risk management.
Professor Byrnes brings together 50 of the industry’s eminent transfer pricing counsel, economists, and financial accountants to provide a comprehensive two-volume “go-to” resource for tax risk management.
Within the first 29 chapters, the U.S. Treasury regulations and jurisprudence are analyzed from an advisory perspective, including chapters on the transfer pricing methods, documentation and examination, advance pricing agreements and mutual assistance, litigation, state issues, and customs. A chapter is dedicated to analyzing the transfer pricing aspects of each step of a U.S. business restructuring.
The next seven chapters of Part II address the OECD’s approach to transfer pricing because many OECD member as well as nonmember countries refer to the OECD Transfer Pricing Guidelines as authoritative or persuasive. The U.S. Treasury refers to the OECD Guidelines for purposes of mutual agreement procedures between competent authorities of treaty partners. These chapters include an exemplary application of value chain analysis, digitalization’s impact on transfer pricing compliance, and hybrid rules interaction with transfer pricing.
Part III is reserved for future chapters analyzing the UN Transfer Pricing Manual and UN transfer pricing guidance for extractive industries because many subscribers have operations in developing economies. Part VI includes a chapter on the impact of EU State Aid cases on APAs. Part V includes eleven industry specific chapters: two risk management chapters, five chapters for financial services topics, and three chapters providing case studies to examine the global value chain of an industry. Part VI contains three country chapters analyzing the national transfer pricing regulations and practice of Brazil, India, and Nigeria. Parts II through Part VI will expand each year to include further analysis and case study chapters.
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Table of contents
PART I UNITED STATES
CHAPTER 1 Overview of Transfer Pricing
CHAPTER 2 Application of Section 482 Before Other Code Sections
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 Comparable Profits Method
CHAPTER 9 The Berry Ratio: More than a Profit Level Indicator?
CHAPTER 10 Transfer Pricing Rules and Methods for Intangible Property
CHAPTER 11 Profit Split Methods
CHAPTER 12 Application of the Comparable Profit Split Method (CPSM) to Business Service Providers
CHAPTER 13 Cost Sharing Arrangements
CHAPTER 14 Transfer Pricing for Services Under the 1968 and 2009 Treasury Regulations
CHAPTER 15 Unspecified Methods
CHAPTER 16 Functional Analysis and Choosing the Best Method
CHAPTER 17 Second-Level Effects of Transfer Pricing Adjustments
CHAPTER 18 Documented Self-Compliance and Transfer Pricing Penalties
CHAPTER 19 IRC Sections 6038A and 6038C: Record-Keeping, Record Production, and Reporting for Foreign-Owned Groups
CHAPTER 20 Examination and Appeals
PART I UNITED STATES (continued)
CHAPTER 21 Advance Pricing Agreements (APAs)
CHAPTER 22 Competent Authority Procedures to Relieve Double Taxation From Transfer Pricing Adjustments
CHAPTER 23 Transfer Pricing Effects of Customs Actions and Customs Effects of Transfer Pricing Actions
CHAPTER 24 Code Provisions That May Preempt IRC Section 482 or Are Alternatives to IRC Section 482
CHAPTER 25 Relationship of Section 482 to Nonrecognition Provisions
CHAPTER 26 Miscellaneous Interactions Between IRC Section 482 and Other Code, Regulatory, or Legal Provisions
CHAPTER 27 Business Restructuring and U.S. Tax and Transfer Pricing Rules
CHAPTER 28 State Tax Transfer Pricing Issues
CHAPTER 29 Transfer Pricing Litigation
CHAPTERS 30–39 Reserved
PART II OECD
CHAPTER 40 U.S. Regulations, OECD Guidelines, UN Manual Compared
CHAPTER 41 The OECD and the U.S. Regarding Risk Allocation
CHAPTER 42 Porter Analysis: A Business Strategy of Amazon.Com Through a Value Chain and Comparative Advantage Analysis of Amazon’s Trademarks and Intangibles
CHAPTER 43 Transfer Pricing Aspects of Business Restructurings—
CHAPTER IX of the OECD Guidelines
CHAPTER 44 Digitalization of the Economy: Emerging Trends and Challenges in Transfer Pricing
CHAPTER 45 Interaction of Transfer Pricing with Anti-Hybrid Rules
CHAPTER 46 The Mutual Agreement Procedure
CHAPTERS 47–59 Reserved
PART III UNITED NATIONS
CHAPTERS 60–74 Reserved
PART IV EUROPEAN UNION
CHAPTER 75 The Impact of EU State Aid Rules on Advance Pricing Agreements
CHAPTERS 76–89 Reserved
PART V INDUSTRY
CHAPTER 90 International Strategy for Transfer Pricing Compliance: A Checklist for Multinationals
CHAPTER 91 Mitigation of Transfer Pricing Risks with ISO 9001 Certification
CHAPTER 92 Financial Industry Transfer Pricing Issues
CHAPTER 93 Determining Arm’s Length Interest and Rent
CHAPTER 94 New Challenges in Defending Intercompany Debt
CHAPTER 95 Applying the Arm’s Length Principle to Performance Guarantees
CHAPTER 96 M&A and Transfer Pricing
CHAPTER 97 The Value Chain: A Study of the Coffee Industry
CHAPTER 98 The Value Chain: A Study of the Tobacco Industry
CHAPTER 99 Transfer Pricing for Extractive Industries
CHAPTER 100 The Effect of Losses on Transfer Pricing
CHAPTERS 101-119 Reserved
PART VI COUNTRIES AND APPENDIXES
CHAPTER 120 Transfer Pricing Rules and Practice of Brazil
CHAPTER 121 Transfer Pricing Rules and Practice of India
CHAPTER 122 Transfer Pricing Rules and Practice of Federal Republic of Nigeria
APPENDIX A Table of Transfer Pricing Acronyms and Definitions
APPENDIX B Announcement 2020-2
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)
Table of Cases
Table of Statutes
Table of IRS Administrative Pronouncements