Transfer Pricing Methods

This book provides a comprehensive analysis of the various transfer pricing methods that are available to today's corporations. It provides a practical focus on the techniques available and their consequences. Chapters are contributed by industry experts and include discussions on: Cost sharing, Comparable profits, Transactional net margin method, Adjustments of interest rates, Foreign exchange adjustment, market share, Organization for Economic Cooperation and Development Guidelines, Life-Cycle analysis, and Use of multiple-year data.

Informationen zum Autor ROBERT FEINSCHREIBER is a practicing attorney and counselor, as well as a former CPA. As a partner in the firm of Feinschreiber & Associates, his clients include foreign-owned U.S. businesses, U.S. exporters, and companies facing international tax issues. He has written and edited many books, including the Transfer Pricing Handbook , Third Edition, Export Handbook , and International Mergers and Acquisitions , all published by Wiley. Klappentext Advanced praise for Transfer Pricing Methods"Feinschreiber and a team of renowned executives have provided the definitive transfer-pricing guide to this challenging area. At a time when many companies are reviewing documents, policies, and procedures, it's wonderful to have a concise, clearly written reference focused on what may be the most critical corporate tax issue."-Charles R. Goulding, Managing Director, TaxCooper Industries, Inc."It is refreshing to find a treatise on transfer pricing that combines practical business considerations, economic theory, and a discussion of technical tax rules in a way that is meaningful not only for large corporate enterprises but also small and medium-sized businesses."-Vikram A. Gosain, JD, CPA, Director of Transfer PricingGeneral Electric Capital Corporation"This well-written book will be useful both to attorneys new to the practice area and to older hands. It includes very helpful discussions on valuation issues that will be particularly useful for in-house counsel and accountants."-Joseph C. Mandarino, PartnerTroutman Sanders, LLP"Feinschreiber and his contributors have cogently explained hundreds of useful facets in the transfer pricing field that have taken others volumes to articulate. The busy professional should consider this book in his or her quest for knowledge in the scintillating tax specialty."-Charles L. Crowley, PartnerITS/Customs and International Trade Practice, Ernst & Young, LLP"Transfer Pricing Methods . . . should become a standard tool for every owner-managed and mid-cap multinational."-Enrique MacGregor, Principal-in-Charge, Transfer Pricing ServicesGrant Thornton LLP"Bob's vast experience in transfer pricing matters has again been captured between the covers of a book. Thank you, Bob, and your contributing colleagues, for producing another valuable helpmate."-Alan Getz, Vice President and General Manager, TaxMitsui & Co., Inc. (U.S.A.)"Feinschreiber's current publication is a practical handbook that presents transfer pricing tools that can assist tax professionals of mid-sized companies to optimize profits, manage cash flows, and moderate taxes in a defensible manner."-Per H. Hasenwinkle, National Practice Leader, Transfer PricingBDO Seidman, LLP Zusammenfassung Advanced praise for Transfer Pricing Methods"Feinschreiber and a team of renowned executives have provided the definitive transfer-pricing guide to this challenging area. At a time when many companies are reviewing documents, policies, and procedures, it's wonderful to have a concise, clearly written reference focused on what may be the most critical corporate tax issue."-Charles R. Goulding, Managing Director, TaxCooper Industries, Inc."It is refreshing to find a treatise on transfer pricing that combines practical business considerations, economic theory, and a discussion of technical tax rules in a way that is meaningful not only for large corporate enterprises but also small and medium-sized businesses."-Vikram A. Gosain, JD, CPA, Director of Transfer PricingGeneral Electric Capital Corporation"This well-written book will be useful both to attorneys new to the practice area and to older hands. It includes very helpful discussions on valuation issues that will be particularly useful for in-house counsel and accountants."-Joseph C. Mandarino, PartnerTroutman Sanders, LLP"Feinschreiber and his contributors have cogently explained hundreds of usefu...

Auteur

ROBERT FEINSCHREIBER is a practicing attorney and counselor, as well as a former CPA. As a partner in the firm of Feinschreiber & Associates, his clients include foreign-owned U.S. businesses, U.S. exporters, and companies facing international tax issues. He has written and edited many books, including the Transfer Pricing Handbook, Third Edition, Export Handbook, and International Mergers and Acquisitions, all published by Wiley.

Texte du rabat

Advanced praise for Transfer Pricing Methods "Feinschreiber and a team of renowned executives have provided the definitive transfer-pricing guide to this challenging area. At a time when many companies are reviewing documents, policies, and procedures, it's wonderful to have a concise, clearly written reference focused on what may be the most critical corporate tax issue." -Charles R. Goulding, Managing Director, Tax Cooper Industries, Inc. "It is refreshing to find a treatise on transfer pricing that combines practical business considerations, economic theory, and a discussion of technical tax rules in a way that is meaningful not only for large corporate enterprises but also small and medium-sized businesses." -Vikram A. Gosain, JD, CPA, Director of Transfer Pricing General Electric Capital Corporation "This well-written book will be useful both to attorneys new to the practice area and to older hands. It includes very helpful discussions on valuation issues that will be particularly useful for in-house counsel and accountants." -Joseph C. Mandarino, Partner Troutman Sanders, LLP "Feinschreiber and his contributors have cogently explained hundreds of useful facets in the transfer pricing field that have taken others volumes to articulate. The busy professional should consider this book in his or her quest for knowledge in the scintillating tax specialty." -Charles L. Crowley, Partner ITS/Customs and International Trade Practice, Ernst & Young, LLP "Transfer Pricing Methods . . . should become a standard tool for every owner-managed and mid-cap multinational." -Enrique MacGregor, Principal-in-Charge, Transfer Pricing Services Grant Thornton LLP "Bob's vast experience in transfer pricing matters has again been captured between the covers of a book. Thank you, Bob, and your contributing colleagues, for producing another valuable helpmate." -Alan Getz, Vice President and General Manager, Tax Mitsui & Co., Inc. (U.S.A.) "Feinschreiber's current publication is a practical handbook that presents transfer pricing tools that can assist tax professionals of mid-sized companies to optimize profits, manage cash flows, and moderate taxes in a defensible manner." -Per H. Hasenwinkle, National Practice Leader, Transfer Pricing BDO Seidman, LLP

Contenu

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. Or…