Transfer Pricing in the US —— A Practical Guide

----- 美国转让定价：实用指南

ISBN: 9789041191960 出版年：2016 页码：242 Lessambo, Felix I Kluwer Law International

In our 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.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 Transfer Pricing Guidelines and Base Erosion and Profits Shifting initiative;? companies’ preparedness for country-by-country reporting;? intellectual property migration; and? documentation and penalties.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. It will also be very useful to state tax authorities.