Transfer Pricing in the US. A Practical Guide

Transfer Pricing in the US is the best and most up-to-date summary of transfer pricing practices available today. In the twenty-first century economy, where multinational enterprises are dominant players, transfer pricing—pricing goods and services transferred within a multinational or transnational company in order to reduce tax burdens and maximize profits—has become the new game. Although transfer pricing is not per se illegal or abusive, in practice its manipulation facilitates large-scale tax evasion and has thus become a major concern of revenue authorities worldwide. This concise but comprehensive analysis focuses on how the United States (US), home of most of the multinationals engaging in abundant and complex transfer pricing arrangements, approaches the task of combating the abusive transfer pricing machinery.

What’s in this book:

Offering practical advice and strategies, illustrated by real case studies, the author explains the key aspects and technicalities of US transfer pricing and the impact of international issues, including such aspects of the subject as the following:

• types of transfer pricing methods and pricing agreements among subsidiaries and affiliates;
• cost-sharing arrangements;
• services transactions;
• European Union tax treatment of US-based multinationals;
• Organisation for Economic Co-operation and Development’s (OECD’s) Transfer Pricing Guidelines and Base Erosion and Profit Shifting initiative;
• companies’ preparedness for country-by-country reporting;
• intellectual property migration; and
• documentation and penalties.

The book begins with a general introduction to transfer pricing and then discusses the current OECD’s Transfer Pricing Guidelines, which form the basis for most transfer pricing rules around the world. The book describes in detail the approved methods for tangible and intangible property, cost sharing, services and the best method rule. Then the book discusses functional analysis for the various methods, including the necessary documentation and penalty rules.

How this will help you:

This concise, practical guide to the latest issues in the rapidly evolving legal regime on transfer pricing in the US context fills the need to gain a firm grasp of transfer pricing rules and practice for corporate counsel and practitioners worldwide, enabling them to prepare compliant solutions and strategies and avoid pitfalls. This book is an indispensable resource for practitioners and academics, and it will be very useful to state tax authorities.