This supplement increases knowledge of transfer pricing regulations. It analyzes primary determinants of transfer pricing, such as the armÂ’s length range, royalties, trademarks, OECDÂ’s transactional net margin method, Treasury DepartmentÂ’s comparable profit method, CPM, foreign exchange, and dumping. The 1994 transfer pricing regulations was hoped to provide the taxpayer and the IRS with a level playing field, but the applications of general principles and guidelines to each transaction, regardless of its size and its complexity, may be daunting. The regulations have had a major impact on the traditional transfer pricing method.
This supplement is divided into seven parts. Part One is about changing the transfer pricing process. Part Two is about analyzing pricing of property and services. Part Three is about applying new transfer pricing method. Part Four is about apportioning taxable income. Part Five is about coordinating tax and non-tax issues. Part Six is about preparing for audits and litigation. Finally Part Seven is about corporate commentary.