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| | New transfer pricing documentation requirements and penalties. |
 | | Since a specified transfer pricing method (comparable uncontrolled price) was used, the taxpayer is confident the price is appropriate and within the provisions of IRC Sec. | | | Upon audit, the IRS accepts all transfer prices as reasonable except for the transfer to Country D. For a transfer of this quantity to this location, the IRS determines the arm's-length range of prices is from $12.50 to $28.50. | | | Transfer prices may be set for managerial purposes so long as adjustments needed to comply with IRC Sec. |
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http://www.nysscpa.org/cpajournal/old/17015440.htm
(2777 words)
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| | Canadian Transfer Pricing Documentation |
| | Transfer prices are prices that companies charge for goods, services, tangible and intangible assets they trade with subsidiaries and similar controlled entities in foreign markets. | | | During the second stage of preparation of the transfer pricing study, we have to estimate a potential transfer pricing exposure, consider the costs and benefits of the study, and prepare the budget. | | | Description of the data and methods considered and the analysis performed to determine the transfer prices or the allocations of profits or losses or contributions to costs, as the case may be, in respect of the transaction. |
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http://www.transferpricing.ca/docum.htm
(4329 words)
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| | Ernst & Young - Financial Services - Transfer Pricing Survey 2005 |
| | Transfer pricing relates to the pricing of internal transactions between related companies or branches, and covers a wide range of issues – such as the provision of services, the cross-border use of information technology systems, or financial transactions involving more than one country. | | | At present, 52 per cent have global transfer pricing policy guidelines, but only 17 per cent prepare the documentation required by tax rules in a globally coordinated manner, and 56 per cent perform economic analysis to demonstrate to tax authorities that their pricing is consistent with the tax standards. | | | The tax rules require that internal pricing policies are consistent with the pricing of comparable transactions between unrelated parties – the “arm’s length” principle. |
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http://www.ey.com/GLOBAL/content.nsf/International/Financial_Services_-_Transfer_Pricing_Survey_2005
(937 words)
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| | Transfer pricing - IT Week |
| | Transfer pricing, the accepted mechanism for allocating profits between subsidiaries for tax purposes, is an accepted part of compliance life. | | | Transfer pricing has become not only a major tax planning opportunity for multinationals, but also an important consideration when streamlining and remodelling business structures. | | | A traditional transfer pricing approach, cost plus, might be used where the centralised procurement is effectively just a managed service. |
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http://www.itweek.co.uk/financial-director/features/2143363/transfer-pricing
(2823 words)
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| | OECD Observer: Transfer pricing: Keeping it at arm’s length |
| | Transfer pricing can deprive governments of their fair share of taxes from global corporations and expose multinationals to possible double taxation. | | | Yet transfer pricing has gained wider attention among governments and NGOs because of another risk: that it could be used to shift profits into low tax jurisdictions even if the MNE carries out little business activity in that jurisdiction. | | | It is likely that the original transfer price set by the MNE was wrong because it left all the profit with the manufacturer, while the Dutch proposal erred on the other side by wanting to transfer all the profit to the distributor. |
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http://www.oecdobserver.org/news/fullstory.php/aid/670/Transfer_pricing:_Keeping_it_at_arm__8217;s_length.html
(1310 words)
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| | Transfer Pricing |
| | Transfer pricing is widely accepted as one of the most significant tax issues facing multinational enterprises and revenue authorities. | | | In general terms, transfer pricing aims to determine the appropriate apportionment of the global profits of a multinational group across various tax jurisdictions. | | | Whilst transfer pricing is often seen as a compliance issue, transfer pricing can also be used as a planning tool to create value for a multinational group. |
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http://www.pwcglobal.com/extweb/service.nsf/docid/036B829F73A37942852567C800367ED0
(225 words)
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| | Transfer Pricing |
| | This price (the transfer price) is used to place a value on the transaction between the two divisions. | | | Often the transfer price is the market price minus the selling expenses. | | | Market price methods: If there is a market for the intermediate good, then the market price is used as the transfer price. |
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http://www.bgu.ac.il/~ariehg/tpintro.htm
(771 words)
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| | CFO: Magazine for Senior Financial Executives: Separate but Unequal - transfer pricing |
| | Transfer prices, the charges recorded by a corporation when its units do business with each other, serve to establish the internal profit structure on which taxes are paid. | | | Lately, though, the authorities have been much more aware of how corporations manage their transfer prices, as governments have sought to increase the amount of income reported and taxed in their jurisdictions. | | | MANAGERS MAKE A DIFFERENCE In both multinational and domestic companies, tax laws permit various techniques for calculating transfer prices, including cost plus profit, arm's-length price less a set discount ("resale minus," as it is known to some), or formulas based on comparable prices or margin measurement. |
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http://www.findarticles.com/p/articles/mi_m3870/is_8_15/ai_55350838
(1358 words)
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| | Transfer Pricing |
| | Transfer pricing is a term used to describe all aspects of intercompany pricing arrangements between related business entities, including transfers of intellectual property; transfers of tangible goods; services and loans and other financing transactions. | | | You need to know whether your internal controls over transfer pricing are sufficient to satisfy a Section 404 end of year audit. | | | You are interested in "best practices" for managing your worldwide transfer pricing policies and procedures. |
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http://www.pwcglobal.com/Extweb/service.nsf/docid/92E194F427FBD3E485256FBE0073DCBD
(211 words)
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| | Transfer Pricing Regulations In India |
| | B on prices and terms determined by Ent. | | | Arm’s length price (ALP) is the internationally accepted transfer pricing standard which must be applied for tax purposes by MNE’s and tax administration. | | | The nature and terms (including prices) of international transactions entered into with each associated enterprise, details of property transferred or services provided and the quantum and the value of each such transaction or class of such transactions. |
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http://www.indiainfoline.com/lega/tapr/trpr.html
(3846 words)
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| | COMMUNITY ECONOMICS: Multinational Operations: Transfer Pricing and Taxation |
| | An easily-followed illustration shows how transfer pricing can be used by multinationals to maximise their profits by tax avoidance and by obtaining tax rebates. | | | Also discussed is the effect of transfer pricing on the tax burden carried by other tax payers. | | | When one part of a multinational organisation in one country transfers (that is, sells) goods, services or know-how to another part in another country, the price charged for these goods or services is called 'transfer price'. |
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http://www.solbaram.org/articles/clm503.html
(2446 words)
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| | Transfer Pricing |
| | The regulations under section 482 generally provide that prices charged by one affiliate to another, in an intercompany transaction involving the transfer of goods, services, or intangibles, yield results that are consistent with the results that would have been realized if uncontrolled taxpayers had engaged in the same transaction under the same circumstances. | | | Section 482 of the Code authorizes the IRS to adjust the income, deductions,credits, or allowances of commonly controlled taxpayers to prevent evasion of taxes or to clearly reflect their income. | | | Pacific Association of Tax Administrators (PATA) Transfer Pricing Documentation Package |
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http://www.irs.gov/businesses/international/article/0,,id=120220,00.html
(155 words)
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| | AICPA Management Accounting |
| | The key is not simply to set individual transfer prices at the right level but to have a defensible system in place for setting transfer prices and to make sure that that system wins government approval in all tax jurisdictions. | | | A transfer pricing mechanism will attribute some of the $9,000 profit to each unit and to the tax return for each country. | | | Generally, its to the taxpayers advantage to establish high transfer prices for goods and services provided by a unit in a jurisdiction with low tax rates. |
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http://www.aicpa.org/pubs/jofa/jul98/carter.htm
(2131 words)
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| | Transfer Pricing |
| | Domestic and international tax authorities have put transfer pricing at the top of their agendas: with more stringent audits, new rules, tax penalties, and documentation requirements, transfer pricing is about to get even more complex. | | | Transfer pricing has become the single most important tax issue facing global companies today. | | | Explore the challenges and opportunities that exist when bringing the transfer pricing function in-house, the implications of new proposed cost-sharing regulations, how Sarbanes-Oxley influences transfer pricing, and, of course, other significant hurdles in advance pricing agreements (APAs) that affect your financial results. |
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http://www.infonexusa.com/usa/U033/overview.html
(326 words)
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| | Transfer Pricing |
| | During this period, however, large companies (under the new definition) are required to make adjustments to their tax returns for transfer pricing transactions not made on an arm's-length basis. | | | Companies should analyse whether they could be exempt from it, the benefits and risk associated with their current transfer pricing strategy, and the level of documentation necessary to support it. | | | A transfer pricing study can help management focus on the overall value of its transfer pricing activities and locations, and improve decision making aimed at maximising total returns. |
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http://www.rsmi.com/triweb/triweb.nsf/body/KTRS62MDY4
(423 words)
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| | Critical Concerns in Transfer Pricing and Practice — www.greenwood.com |
| | Anticipating increased scrutiny of MNC transfer pricing practices from governments and other external stakeholders, Abdallah outlines a set of practical recommendations for creating a successful transfer pricing system that maximizes value for the company while remaining sensitive to local policies in all of the countries in which it operates. | | | Its complexity is compounded by the impact of e-commerce, speeding the flow of goods and services; "intangible" assets, such as intellectual property, whose value is difficult to quantify; and the activites of policymakers around the world to update their tax laws and regulations, in efforts to close loopholes that have historically encouraged tax avoidance. | | | In Critical Concerns in Transfer Pricing Policy and Practice, Wagdy Abdallah provides an in-depth overview of these recent trends and developments, and considers their implications for the management of MNCs. |
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http://www.greenwood.com/books/BookDetail.asp?dept_id=1&sku=Q561
(303 words)
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| | GTI.org - Transfer pricing |
| | In some countries, transfer pricing rules are also applicable to intra-border transactions. | | | Transfer pricing traditionally occurs where goods or services move between related parties cross-border. | | | They negotiate with local tax authorities to gain agreement on transfer pricing policies and seek rulings for transactions already completed |
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http://www.gti.org/services/tax/transfer.asp
(313 words)
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| | KRM Transfer Pricing Software |
| | Transfer pricing of non-maturity assets and liabilities using the analytics of Kamakura’s non-maturity valuation module KRM-dc | | | Kamakura’s transfer pricing clients range in size from $6 billion in assets to $500 billion in assets. | | | KRM-tp is the first transfer pricing module in the industry to offer full option-adjusted transfer pricing, with arbitrary degrees of consumer “rationality,” all done on a multi-currency basis. |
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http://www.kamakuraco.com/krm_tp.htm
(543 words)
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| | Mitchel Zuniga & Smith Tax and Business Services - page one - International Tax, Transfer Pricing |
| | The transfer pricing study is also used when seeking an Advanced Pricing Agreement (APA) with the IRS or foreign governments. | | | The increased instances of a transfer pricing audit and the addition of multiple reporting requirements leave the inexperienced practitioner and client at great risk. | | | Additionally, since we have a broad range of experience in state tax issues, we can advise the client on how transfer pricing decisions are impacted by state tax law. |
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http://www.mitchelzuniga.com/pageone.html
(834 words)
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| | SSRN-Strategic Transfer Pricing, Absorption Costing and Vertical Integration by Robert Göx |
| | When transfer prices are observable, both firms' headquarters will exclude their marketing division from the external input market and charge a transfer price above the market price of the intermediate product to induce their marketing managers to behave as softer competitors on the final product market. | | | When transfer prices are not observable, strategic transfer pricing is not an equilibrium, and the optimal transfer price equals the market price of the intermediate product. | | | Moreover, when the firms' products are close substitutes, the strategic benefits of full cost based transfer pricing can provide incentives to maintain a production department that would not be able to survive as a separate firm in the long run. |
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http://papers.ssrn.com/sol3/papers.cfm?abstract_id=98661
(332 words)
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| | Financial Opinions & Advisory Services -Transfer Pricing |
| | Houlihan Lokey Howard & Zukin has executed a broad range of transfer pricing and intangible asset valuation engagements for clients ranging from law firms to private equity investors to corporate tax directors. | | | Tax authorities, recognizing the potential for income shifting to lower tax jurisdictions, are becoming more vigilant in enforcing transfer pricing regulations in today’s globally-connected economy. | | | Reviewing a company’s activities for compliance with transfer pricing regulations and identifying tax savings opportunities and potential tax audit issues. |
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http://www.hlhz.com/main.asp?p=CORP_FINADV_TransferPricing
(606 words)
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| | Funds Transfer Pricing (FTP) |
| | BancWare FTP enables you to access historical transfer prices and spreads as a resource for performance reporting, planning, budgeting, and control functions throughout the institution. | | | It has extremely flexible transfer pricing methodologies that range from very simple to highly sophisticated, and provides profitability information essential to making product pricing, asset allocation and compensation decisions. | | | BancWare Funds Transfer Pricing (FTP) provides financial institutions with the most effective decision-making platform for customer, organizational and product profitability, product pricing and asset allocations. |
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http://www.sungard.com/products_and_services/stars/bancware/solutions/fundstransferpricingftp.htm
(129 words)
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| | Transfer Pricing |
| | Transfer pricing involves the terms and prices at which related parties sell (or should sell) goods or services to another. | | | However, transfer pricing studies can often unearth possible tax minimization techniques that were previously unidentified, or the studies can justify price adjustments that have been enacted or delayed. | | | To combat potential losses of income tax revenue, more and more countries are adopting rules requiring the completion of a transfer pricing study to prove the taxpayer's reporting position by comparing its achieved results with those of comparably-situated unrelated parties. |
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http://www.rsmi.com/triweb/triweb.nsf/body/CSTS5DNFN4GHUT5KLJP2
(467 words)
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| | International Tax Review |
| | For asset management, the key function is risk management, perhaps best summarized as being a decision-making function, constantly assessing whether to keep a risk position open in the hope of favourable market movements, or to hedge that risk by means of derivatives, or to dispose of the asset altogether. | | | The OECD's most recent report on applying transfer pricing principles to banking permanent establishments (Discussion Draft on the Attribution of Profits to Permanent Establishments (PEs): Part II (Banks)) (the Discussion Draft) has a number of important implications for taxpayers in this business sector. | | | To determine the amount of capital that would be required to support its activities, if the PE were a stand-alone entity, first, a determination of risks and assets attributable to the PE needs to be made. |
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http://www.internationaltaxreview.com/?Page=17&ISS=13155&SID=488119
(2052 words)
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| | UWLS Transfer Pricing Workshop |
| | This Transfer Pricing Workshop will be oriented toward beginning to intermediate tax practitioners who have direct or indirect responsibility for performing transfer pricing analyses and/or preparing transfer pricing documentation or planning reports. | | | Bonano advises clients on transfer pricing and international tax issues including: cost sharing, technology transfer, section 6662 documentation, APAs, permanent establishment, debt vs. equity, foreign withholding, research credit, and other related issues. | | | Bonano's practice focuses on transfer pricing and international tax and he has significant experience with transfer pricing controversies. |
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http://www.law.washington.edu/tax/tpw/ca
(784 words)
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| | EUROPA - Taxation and Customs Union / Transfer pricing forum |
| | In addition, the improvement of Member States' co-ordination in order to reduce compliance costs and lessen the uncertainty relating to transfer pricing are considered of major importance in the short term. | | | The European Commission on 10 November adopted a proposal for a Code of Conduct that would standardise the documentation that multinationals must provide to tax authorities on their pricing of cross-border intra-group transactions ('transfer pricing' documentation). | | | Commission Communication (COM/2005/543 of 7/11/2005) on the work of the EU Joint Transfer Pricing Forum on transfer pricing documentation for associated enterprises in the EU and proposal for a Code of Conduct on transfer pricing documentation for associated enterprises in the EU Report |
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http://europa.eu.int/comm/taxation_customs/taxation/company_tax/transfer_pricing/forum/index_en.htm
(751 words)
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| | Transfer Pricing - Deloitte & Touche S.R.L. |
| | In 2003, we constituted the Transfer Pricing Andean Group with our offices in Colombia and Venezuela, as the most efficient and effective manner to provide regional transfer pricing services, with uniform approaches and strategies and the consequent costs reductions for our clients. | | | It comprises over 15 specialised economists, with a local and international experience in the matter, who are supported by Deloitte’s Global Transfer Pricing Team and the tax lawyers and accountants from our Tax and Legal Advice division, comprising over 40 professionals. | | | In the case of controversies requiring a bi-national or multinational effort, Deloitte Competent Authority Team, comprising top level professionals with previous experience as responsible officials in the entities competent in transfer pricing in various countries, will be available to structure negotiation strategies. |
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http://www.deloitte.com/dtt/section_node/0,1042,sid=84311,00.html
(476 words)
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| | Transfer Pricing Handbook by Robert Feinschreiber |
| | Transfer pricing has a multibillion-dollar impact on corporations worldwide. | | | Only half of multinationals in recent pricing transfer audits were able to defend their prices well enough | | | With the two volumes of Transfer Pricing Handbook, Second Edition, you'll get a complete, practical analysis of the final transfer pricing regulations, including cost sharing, valuation of intangibles, and audit strategies. |
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http://www.transferpricingconsortium.com/TPhandbook.html
(421 words)
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| | HSSK Group - Intercompany Transfer Pricing, including Intellectual Property - IRC§ 482 |
| | Every United States firm, with foreign operations - regardless of size - is required to implement and document their transfer pricing in compliance with IRC §482. | | | This generates an escalating call for multinational firms to focus on their transfer pricing policies and to seek innovative solutions to them. | | | The corporate taxpayer may best support his position by having the economic analysis and transfer pricing documentation prepared by an independent expert. |
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http://www.hsskgroup.com/valuation/federal/intercompany.asp
(188 words)
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| | BNA Tax Management Transfer Pricing Featured Interview |
| | 96-53, 1996-2 C.B. 375, APAs are agreements between the IRS and individual taxpayers on a method that correctly calculates the "arm's-length" intercompany price to ensure that companies are not using related-party transactions to improperly shift profits to other jurisdictions (5 Transfer Pricing Report 427, 11/27/96). | | | The legislation amended Sections 6110 and 6103 to shield APAs from public disclosure by providing that the agreements and their background information are confidential tax return information (8 Transfer Pricing Report581, 10/27/99; 7 Transfer Pricing Report 650, 1/13/99). | | | The Service acknowledged in 1999 that APAs were subject to disclosure under Section 6110 and agreed to consult with individual taxpayers and, when appropriate, foreign tax authorities before releasing redacted APAs (8 Transfer Pricing Report 710, 12/22/99). |
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http://law.gsu.edu/gcarey/intltax/jc_apafeature.htm
(1553 words)
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| | Tax Executive, The: Recent developments in Canadian transfer pricing |
| | With effect in 1999, there is a transfer price related penalty, equal to 10 percent of the amount by which Canadian income has been understated because of transfer prices not conforming to the arm's-length principle. | | | Nevertheless, the almost twin cousin developed by the OECD (the net transactional margin method (TNMM)) has not only mainly dissolved the conflict, but in its September 1999 revised information circular, CCRA reluctantly acknowledged that in some circumstances CPM (and not merely its twin TNMM) might be appropriate. | | | (3) In the absence of specific statutory rules for applying the arm's-length principle, Canada Customs and Revenue Agency (CCRA) takes the position that determinations are to be made in accordance with the transfer pricing "methods" developed (mainly on the basis of the U.S. regulations) by the Organisation for Economic Cooperation and Development (OECD). |
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http://www.findarticles.com/p/articles/mi_m6552/is_3_55/ai_106097231
(1028 words)
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| | Transfer Pricing Examinations (2/96) |
| | This issue arises in transfer pricing litigation when counsel for the Service seeks to interview former employees of the taxpayer. | | | See the discussion of this issue in 2 Tax Management, Transfer Pricing Report 783 (Apr. 13, 1994). | | | Such officers will be the most knowledgeable witnesses available concerning the taxpayer's business and the business justification supporting the transfer pricing. |
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http://www.pmstax.com/intl/bull9602.shtml
(7889 words)
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| | Transfer Pricing Worldwide Documentation and Planning System |
| | TPA's flexible methodologies aid management in determining transfer prices for tax and other purposes such as global reengineering strategies. | | | TPA helps build a comprehensive transfer pricing report to avoid U.S. and foreign country documentation penalties. | | | Global transfer pricing services from Deloitte Tax LLP |
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http://www.corptax.com/www/TransferPricing.nsf/Documents/TransferPricing
(270 words)
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| | Moss Adams LLP: Services -- Tax Services -- International Tax -- Transfer Pricing |
| | The rules require that companies adequately document the pricing policies of their inter-company transactions. | | | Clients with foreign affiliates who enter into transactions for goods and services with each other are subject to transfer pricing rules. | | | Is a domestic corporation (whether or not ultimately US-owned); and has international cross-border transactions (involving tangible personal property, royalties, or services) with related parties, where the US is one of the countries involved; and |
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http://www.mossadams.com/services/tax/intltransfer.htm
(294 words)
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| | Wiley::Transfer Pricing Handbook, Third Edition, 2 Volume Set, 3rd Edition |
| | This handbook provides a comprehensive analysis of the transfer pricing issues that affect taxpayers and tax collectors alike. | | | Provides non-tax transfer pricing guidance on such issues as imported merchandise, customs-related issues, and customs appraisement | | | The 2002 Supplement includes updates to both Transfer Pricing 3e and Transfer Pricing International. |
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http://www.wiley.com/WileyCDA/WileyTitle/productCd-0471419249.html
(361 words)
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| | Transfer Pricing:Topic |
| | To determine tax liability in each jurisdiction, the right price (arm's length price) has to be applied, the OECD has issued guidelines on this principle to avoid double taxation. | | | The increased speed an mobility of business activities and cross-border transactions resulting from internet usage has particular implications for applying transfer pricing methods and for taxing business profits. | | | The discussion covered treaty, transfer pricing and indirect taxes issues involved in business reorganisations. |
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http://www.oecd.org/topic/0,2686,en_2649_33753_1_1_1_1_37427,00.html
(409 words)
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| | NERA Economic Consulting Practice Area |
| | This results in transfer pricing solutions that meet both clients' business objectives and the arm's length requirements imposed by national tax authorities. | | | NERA's Transfer Pricing Practice helps clients minimize tax risk, and optimize use of their global resources. | | | The team utilizes market-based pricing techniques (including value-chain and industry structure analyses), benchmarking studies and rigorous valuation methodologies to design intercompany pricing policies grounded in sound business strategy and well-established economic principles. |
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http://www.nera.com/PracticeArea.asp?PA_ID=68
(147 words)
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| | Transfer Pricing |
| | FSA 200023014 (consideration of transfer pricing methodologies, including market capitalization method, as best method for determining arm's length buy-in payment under Treas. | | | FSA 200103024 (value of stock options is item of compensation cost for tax purposes that must be included in pool of costs shared under qualified cost sharing arrangement) | | | U.S. Treasury Department and IRS, Study of Intercompany Pricing (1988 White Paper), 1988-2 C.B. General Explanation of the Tax Reform Act of 1986, |
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http://www.intltaxlaw.com/shared/transfer/frontpage.htm
(1085 words)
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| | Tax Planning International Transfer Pricing |
| | Find expert advice to help you set a transfer pricing policy and apply tax rules once you've established your strategy. | | | If you trade with related companies in other jurisdictions, whether your business is traditional or electronic, Tax Planning International Transfer Pricing can help you minimize tax and avoid penalties. | | | It provides detailed, expert analysis of legislative developments in the growing world of transfer pricing regulation. |
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http://www.bna.com/products/tax/tptn.htm
(250 words)
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| | Tax Executive: Temporary and proposed section 482 regulations. (intercompany transfer pricing)@ HighBeam Research |
| | However, proposed section 6662(e) and 6662(h) regulations impose excessive burdens on taxpayers through the accuracy-related penalties for errors in transfer pricing. | | | The proposed IRC section 482 regulations issued by the IRS on Jan 13, 1993, confirm the arm's-length standard and bring the US closer to international standards on intercompany transfer pricing. | | | The maintenance of contemporaneous documentation is costly, burdensome and pointless when an audit trail of intercompany transactions would serve just as well. |
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http://www.highbeam.com/library/doc0.asp?DOCID=1G1:14260947&refid=holomed_1
(197 words)
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| | BNA Tax Management Product Information--Transfer Pricing Report |
| | Shows how leading companies have structured their pricing to comply with various government compliance and audit policies. | | | This biweekly publication goes beyond the news, providing both U.S. and foreign practitioners’ perspectives and insights, feature articles, and expert analysis on how corporations are handling complex transfer pricing challenges. | | | Archive now includes all issues of Transfer Pricing Report back to 1992 |
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http://www.bnatax.com/tm/transferpricing_details.htm
(288 words)
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| | Wiley::Transfer Pricing Methods: An Applications Guide |
| | "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." | | | "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." | | | The busy professional should consider this book in his or her quest for knowledge in the scintillating tax specialty." |
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http://www.wiley.com/WileyCDA/WileyTitle/productCd-0471651230,descCd-description.html?print=true
(296 words)
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| | BNA Tax Management Product Information--Transfer Pricing |
| | Special Reports throughout the year focus on such areas as economic factors in transfer pricing, foreign country rules and practices, and advance pricing agreements. | | | Difficult-to-obtain information on transfer pricing developments in other countries | | | Demo of Transfer Pricing on BNA Tax Web Library |
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http://www.bna.com/tm/transfer_pricing.htm
(143 words)
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| | Transfer Pricing |
| | It explains how to base a transfer price on market prices, costs, or negotiations. | | | Chapter 19 explains the purpose and role of transfer pricing. | | | It discusses the implications of transfer pricing in a multinational company. |
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http://highered.mcgraw-hill.com/sites/0072474343/student_view0/chapter_19
(208 words)
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| | Complete Transfer Pricing Suite |
| | Whether you are drafting an agreement or analyzing the most current issues, this treatise should be among your primary resources. | | | RIA recommends these items to complement Complete Transfer Pricing Suite: | | | The authors develop the substantive law (some 450 cases and relevant regulations), then apply these principles to: transfer pricing studies, presenting positions in a controversy or litigation context, obtaining advance pricing agreements (APAs) and responding to a summons or examination. |
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http://ria.thomson.com/estore/detail.aspx?ID=WCTP
(232 words)
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| | Ceteris Transfer Pricing Tax Valuation Expertise |
| | is a flexible approach to transfer pricing that is tailored to meet your specific business needs. | | | Our transfer pricing advisors can seamlessly collaborate with any accounting, tax and planning group through each of our | | | of over 50 leading transfer pricing advisors with "Big 4" and industry expertise spans the Americas, Europe and Asia with North American offices in Atlanta, Chicago, New York, San Diego and Toronto. |
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http://www.ceterisgroup.com
(87 words)
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| | Disney Cruise Line, Disney Cruises - transportation, check in |
| | Disney Cruise Line transfers are not always the cheapest option if you have more than 3 in your party. | | | When you pay per person instead of flat rates, you spend more than you realize. | | | The first, and more expensive option is to purchase transfers with your Disney Cruise Line reservation. |
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http://www.wdwinfo.com/wdwinfo/cruise-new/cr-transportation.htm
(975 words)
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| | U.S. International Transfer Pricing |
| | RIA recommends these items to complement U.S. International Transfer Pricing: | | | U.S. International Transfer Pricing, Second Edition thoroughly examines the substantive law (some 450 cases, plus thousands of pages of regulations) and then applies these principles to such initiatives as: transfer planning studies, presenting positions in the context of litigation or controversy, obtaining an Advance Pricing Agreement, responding to a summons or examination. | | | Provides essential transfer pricing guidance for U.S.-based companies and practitioners |
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http://ria.thomson.com/estore/detail.aspx?ID=WINTP&productInfo=Authors
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| | Control with Fairness in Transfer Pricing (HBSP) doi:10.1225/83606 |
| | Control with Fairness in Transfer Pricing (HBSP) doi:10.1225/83606 | | | Accounting for Success: A History of Price Waterhouse in America--1890-1990 (Hardcover) | | | Please click on the choices below to learn more about this product. |
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http://doi.contentdirections.com/mr/hbsp.jsp?doi=10.1225/83606
(128 words)
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| | Your global transfer pricing solution. Your transfer pricing ambition. |
| | Transfer Pricing Associates is an independent global provider of transfer pricing and tax valuation services with headquarters in Amsterdam, and offices in Auckland, Buenos Aires, London, New York, Paris, Sao Paulo, Sydney, Valencia, Warsaw, and Zurich. |
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http://www.transferpricingassociates.com
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