Transfer pricing has a multibillion-dollar impact on corporations worldwide. Governments are increasing their strict enforcement. Failure to comply with sections 482, 6038A, and 6662 can lead to heavy penalties hitting your organization. But there's help.
Section 482. Completely covered. 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. You'll explore current taxation under IRC Sections 482, 6038A, and 6662 - plus legislative and regulatory developments from 1986 to the present. This contributed volume written by international tax experts gives you the global scope of transfer pricing. You'll also review a discussion of taxation of foreign-owned U.S. corpora-tions. Avoid IRS penalties by mastering the transfer pricing regulations!
Why get the facts on transfer pricing?
- Only half of multinationals in recent pricing transfer audits were able to defend their prices well enough
to avoid adjustments.
- 63% of the parent companies said they've faced recent transfer pricing audits. Half of those had their transfer
prices adjusted by authorities.
- 80% of corporations surveyed expect to face a transfer pricing examination somewhere in the world within the next two years.
"The format of the book, in which each chapter is written by a different expert, brings a wealth of perspectives and expertise... The soup to nuts' organization of the book allows the reader to concentrate only on areas of immediate concern..."
"The book covers every relevant topic that impacts the area of transfer pricingthe contributing authors are practitioners whose experience will lend a depth of insight"
Vice President and General Manager, Tax
Mitsui & Co. (U.S.A.)
"This book is fascinatingRobert Feinschreiber always gets to the heart of the matter."
National Director of International Taxation and Tax Partner
Table of Contents
Part One Introduction to Transfer Pricing
Part Two Changing the Transfer Pricing Process
Part Three Analyzing Sales of Tangible Property for Transfer Pricing Purposes
Part Four Applying New Transfer Pricing Methods
Part Five Intangibles and Services for Transfer Pricing
Part Six Apportioning Taxable Income
Part Seven Transfer Pricing Penalties
Part Eight Foreign-Owned U.S. Corporations
Part Nine Preparing for Transfer Pricing Audits and Litigation
Part Ten Coordinating Tax and Nontax Transfer Pricing Issues