Transfer Pricing Methods: An Applications Guide / Edition 1

Transfer Pricing Methods: An Applications Guide / Edition 1

by Robert Feinschreiber, Feinschreiber
     
 

ISBN-10: 0471573604

ISBN-13: 9780471573609

Pub. Date: 03/08/2004

Publisher: Wiley

There has never been an easy-to-use and convenient book that addresses salient and fundamental transfer pricing issues . . . until now. Designed to specifically assist mid-sized businesses facing transfer pricing issues now and in the future, Transfer Pricing Methods is a comprehensive guide that provides in-depth coverage of various transfer pricing methods and

Overview

There has never been an easy-to-use and convenient book that addresses salient and fundamental transfer pricing issues . . . until now. Designed to specifically assist mid-sized businesses facing transfer pricing issues now and in the future, Transfer Pricing Methods is a comprehensive guide that provides in-depth coverage of various transfer pricing methods and applications that are available to today’s mid-sized corporations.

An invaluable reference for all tax managers, CEOs, and CFOs, Transfer Pricing Methods provides a practical focus on the techniques available and their consequences. Featuring contributions from industry experts, complete coverage includes:

  • Comparable profits methods
  • Cost sharing
  • Transactional net-margin method
  • Adjustments of interest rates
  • Resale price techniques
  • Benefiting from the cost-plus method
  • Market share
  • Organisation for Economic Co-operation and Development guidelines
  • Life-cycle analysis
  • Use of multiple-year data

Transfer Pricing Methods presents in-depth coverage in five accessible parts:

Understanding the Transfer Pricing Process:
Addresses business issues, general principles, and tax guidelines, with practical transfer pricing advice.

Applying Specific Transfer PricingTechniques:
Examines the specifics of each transfer pricing method.

International Transfer Pricing Issues:
Focuses on international and foreign issues, including the impact of the foreign-owned U.S. corporation provisions that often serve as a backstop to transfer pricing regulations.

Avoiding Transfer Pricing Penalties:
Discusses the penalties for transfer pricing errors or just bad guesswork, examines how to escape these pitfalls, and examines the transfer pricing penalty for contemporaneous documentation infractions.

Advanced Transfer Pricing Issues:
Covers the ownership of intangibles, cost analysis, life cycle issues, and antitrust considerations.

Product Details

ISBN-13:
9780471573609
Publisher:
Wiley
Publication date:
03/08/2004
Pages:
320
Product dimensions:
10.00(w) x 7.00(h) x 0.81(d)

Table of Contents

Preface.

PART ONE: UNDERSTANDING TRANSFER PRICING.

Chapter 1. Practical Aspects of Transfer Pricing.

Chapter 2. Business Facets of Transfer Pricing.

Chapter 3. General Principles and Guidelines.

Chapter 4. Transfer Pricing Basics.

PART TWO: APPLYING SPECIFIC TRANSFER TECHNIQUES.

Chapter 5. Comparable Uncontrolled Price Method, Resale Price Method, and Cost-Plus Method.

Chapter 6. Comparable Profits Method.

Chapter 7. Comparable Uncontrolled Transaction Method for Intangibles.

Chapter 8. Transfer Pricing for Services.

Chapter 9. Cost Sharing.

Chapter 10. Profit Methods.

PART THREE: FOCUS ON INTERNATIONAL TRANSFER PRICING ISSUES.

Chapter 11. Foreign-Owned U.S. Corporations Reporting.

Chapter 12. Organization for Economic Cooperation and Development Guidelines.

Chapter 13. Transactional Net Margin Method.

PART FOUR: AVOIDING TRANSFER PRICING PENALTIES.

Chapter 14. Transfer Pricing Penalties.

Chapter 15. Transfer Pricing Penalty Exclusion for Contemporaneous Documentation.

PART FIVE: ADVANCED TRANSFER PRICING ISSUES.

Chapter 16. Advanced Transfer Pricing.

Chapter 17. Unfolding Transfer Pricing Issues.

Index.

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