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PROPOSALS FOR REVISING THE Transfer pricing AUDIT STRUCTURE

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Corporate Business Taxation Monthly

Corporate Business Taxation Monthly 2002年第8期3卷 3页

作者： Feinschreiber, Robert Kent, Margaret

Deals with the proposal to revise the Transfer pricing audit structure in the U.S. Categories of Transfer pricing methodologies; Suggestions for improving the Transfer pricing audit structure; Benefits from divergent ... 详细信息

关键词： Transfer pricing Auditing pricing

Optimal Transfer pricing for the Multinational Firm

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Financial Management (1972) 1972年第3期1卷 74-87页

作者： J. William Petty II Ernest W. Walker Assistant Professor of Finance Texas Tech University Professor of Finance University of Texas Austin Consulting economist National Association of Credit Management

Intercorporate pricing for the multinational firm is a prime problem. Several key operational needs may be fulfilled by means of effective Transfer pricing policies.

关键词： Income taxes Local economy Corporations Tax brackets Imports Subsidiary companies Transfer pricing

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Richard A Clark

International Tax Review

International Tax Review 2009年 173-173页

The article profiles Richard A. Clark, who has over 20 years of Transfer pricing experience with the law firm Deloitte Tax LLP, located in Washington, D.C. His law practice covers helping international business enterprises in developing intercompany pricing strategies for tax planning. He has an extensive experience collaborating with major foreign and U.S. multinational companies in several industries. He has published articles on Transfer pricing as an editor-in-chief and columnist for the "Journal of Global Transfer pricing."

关键词： LAWYERS LAW firms Transfer pricing TAXATION

THE PROPOSED Transfer pricing REGULATIONS: COMMENTS AND CONCERNS

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National Tax Journal 第3期45卷 233-238页

作者： Dicker, Laurie J. Carlson, George N

This article focuses on the concerns over the proposed Transfer pricing regulations in the U.S. The proposed Transfer pricing regulations include important changes to the internationally recognized arm's-length standard. The proposed regulations specify that the rules for evaluating Transfers of intangible property apply to any transaction in which the Transfer of an intangible occurs through Transfers of tangible property or services, if the income attributable to the intangible is material in relation to the income attributable to the tangible property or services to which it relates. The commensurate-with-income standard as implemented in the proposed regulations seems to allow for not only periodic adjustment to royalty rates or Transfer prices, but also for retroactive adjustments. The comparable profit interval test and methodology in the proposed regulations rely on measures of operating income. Since this test and methodology are likely to be the primary Transfer pricing models, comparisons of operating income will replace current comparisons of prices, gross profit margins, and royalty rates. The proposed regulations are silent with respect to the sharing between related parties of fluctuations in exchange rates. Traditional IRS thinking on this issue bad been that distributors should be insulated from exchange rate risk, but that notion does not seem to be based either on economic theory or the evidence from third party license and distribution agreements.

关键词： Transfer pricing price regulation TAXATION INTERCOMPANY transactions ECONOMIC policy

Economic models of Transfer pricing in decentralized firms

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European Accounting Review 第3期4卷 585-586页

作者： Slof, Eric John Universitat Pompeu Fabra

This article discusses economic models of Transfer pricing in decentralized firms. A particular interest is taken in the economic perspective. Information comes predominantly from surveys, which typically collect data expressed in accounting terms. The fact that the economic approach uses a different set of concepts is often ignored, while the translation from accounting to economic concepts and vice versa is hardly straightforward. Particularly relevant in this respect is the fact that accounting variable costs are generally not an approximation of economic marginal costs, and hence the former should not be used as a proxy for the latter. It is concluded that empirical data about Transfer practice must be used with the greatest circumspection when testing economic models; and that so far, most conclusions drawn from these data are premature. Taking the relationship between accounting and economics into account, the thesis argues that even the logic of the least sophisticated economic contributions to the Transfer-pricing literature can be reconciled with most observed practices.

关键词： Transfer pricing COST accounting ACCOUNTING ECONOMIC models ECONOMETRICS ECONOMICS -- Statistical methods MACROECONOMICS MATHEMATICAL models ADVANCE pricing agreements CROSS border transactions INTERNATIONAL business enterprises LABOR costs PROXY statements VARIABLE costs

UWARUNKOWANIA DECYZJI W TRANSAKCJACH PODMIOTÓW POWIĄZANYCH

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Operations Research and Decisions

Operations Research and Decisions 2007年第1期 79-90页

作者： KROIK, Janusz MALARA, Zbigniew Instytut Organizacji i Zarządzania Politechnika Wrocławska ul. Smoluchowskiego 25 50-372 Wrocław

Along with the development of world and regional economy the importance of the Transfer pricing is growing up. In the paper, some results of research accomplished in Poland, in 2006, are partly presented. It was carried out upon a large number of Polish enterprises belonging to capital groups (financial holdings). Based on the final results, some important aspects of Transfer pricing are briefly presented and interpreted. The General factors connected with decision making as far as Transfer pricing is concerned are discussed as well. A final assessment was made upon the results of decision making within transaction process linked enterprises and their influence on Transfer pricing fixed mutually. The conclusions also included other final results obtained concerning the under consideration topic in Poland. They confirmed the tendency observed in the last years according to which the determinants treated in theory as fundamental factors in creating Transfer pricing become gradually changed. [ABSTRACT FROM AUTHOR]

关键词： decision making Transfer pricing ceny Transferowe podejmowanie decyzji Language of Keywords: English Polish

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United States

International Tax Review

International Tax Review 2007年 495-532页

作者： Schrotenboer, Ronald rschrotenboer@fenwick.com Forst, David dforst@fenwick.com Partners in the tax group of Fenwick & West Mountain View California

The article presents an update on tax law in the U.S. There were changes made to the subpart F rules and Transfer pricing regulations. In May 2006, Subpart F was enacted to prevent Subpart F income for payments between foreign subsidiaries. New temporary regulations were issued and include rules on controlled services and intellectual property transactions.

关键词： TAXATION -- Law & legislation Transfer pricing TAX planning INTERNATIONAL business enterprises COMMERCIAL law

Transfer pricing Audits in Mexico: Analysis of the Process and Defense Options

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Tax Management International Journal

Tax Management International Journal 2010年第7期39卷 399-401页

作者： Barrett, Fred Calatayud, Adolfo PricewaterhouseCoopers LLP Mexico City Mexico

The article discusses the Transfer pricing audit program introduced by the Mexican tax authority, the Tax Administration Service, that covers both domestic and international associated-party deals in different sectors like multinational groups and big and medium-sized national businesses. It examines how can taxpayers can deal with the review process conducted by the Mexican tax authority in accordance with the account income tax treaties signed by the country. It cites the Transfer pricing adjustments to focus on like the indirect effects.

关键词： Transfer pricing Auditing procedures Tax administration & procedure Taxpayer compliance Double taxation conventions

Tax court upholds regulatory requirement for readily ascertainable FMV in connection

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Tax Management Compensation Planning Journal

Tax Management Compensation Planning Journal 第11期21卷 287页

Presents the `Cramer versus Comr.' case showing the Tax Court's upholding of the validity of the Internal Revenue Service's Section 83 regulations. Factors required for non-publicly traded options' readily ascertainab... 详细信息

关键词： TAXATION Transfer pricing