By Elizabeth King
Transfer pricing is frequently pointed out because the most vital tax factor that multinational companies face. This ebook is an exceptionally useful gizmo for practitioners and tax administrators grappling with complicated and contentious move pricing problems with numerous types. It encompasses a sequence of hugely specified case stories, which draw at the author's twenty years as a central authority economist focusing on move pricing and valuation, a move pricing economist with cost Waterhouse, and, finally, an autonomous advisor. those case reports elucidate the categories of intercompany transactions that tax specialists frequently scrutinize, lay out how one may still pass approximately interpreting such transactions below the prevailing regulatory regime in significant aspect, and illustrate a few proposed substitute methods which may considerably decrease compliance expenditures and the frequency of move pricing disputes.
Practitioners and tax administrators will locate the case reviews super important in formulating defensible move pricing guidelines. The case experiences can also be precious in assessing tax publicity caused by intercompany pricing practices, as required below FASB Interpretation No. forty eight (FIN 48). Tax coverage analysts will locate the overview and critique of present equipment and the improvement of different proposals thought-provoking and compelling.
The publication is split into 3 elements: half I encompasses a certain evaluation and critique of person move pricing tools and the industrial premises that underpin them. half II incorporates a dialogue of proposed replacement move pricing tools. half III includes the aforementioned sequence of 8 case stories, encompassing a extensive diversity of move pricing matters. worldwide buying and selling and likely different types of Internet-based companies, which the present move pricing regime doesn't competently deal with, are one of the matters lined. each one case learn is analyzed less than either the prevailing move pricing regime and a number of proposed methods.
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Extra info for Transfer Pricing and Corporate Taxation: Problems, Practical Implications and Proposed Solutions
However, the more recent CIP relaxes this restriction. The income method is based on the aforementioned assumption that the group member contributing pre-existing intangible assets would only enter into a cost-sharing arrangement if such participation is at least as advantageous as the best feasible alternative. The income method can be applied in conjunction with the comparable uncontrolled transaction (CUT) method or the comparable profits method. As indicated above, the entity contributing pre-existing intangible assets could opt instead to incur all intangibles development costs itself, and license the resulting intellectual property to affiliated companies.
14 Relatedly, buyers may incur significant costs simply to ascertain whether substitutable alternatives exist; such costs may deter them from doing so. Therefore, market pressures that might serve to equalize royalty rates across licensors rarely come into play. S. regulations would not suffice to ensure that two separate licensors would independently negotiate the same royalty rate and terms for the same set of rights to comparable intellectual property. S. firms can, and frequently do, request confidential treatment of information relating to the license or sale of intangible assets.
That is, the net present value of the project must be positive. However, this does not mean that, having opted to establish a cost-sharing arrangement, all income attributable to pre-existing and yet-to-be-developed intangible assets should flow to USP. Rather, USP should systematically compare the discounted present value of after-tax free cash flows associated with the following two options: 1. Fund the further development of intangibles independently and exploit the resulting assets directly or through licensing (or a combination thereof) on a worldwide basis; or 2.