Transfer Pricing and Corporate Taxation

Problems, Practical Implications and Proposed Solutions

  • Elizabeth┬áKing

Table of contents

  1. Front Matter
    Pages I-IX
  2. Introduction

    1. Front Matter
      Pages 1-1
    2. Elizabeth King
      Pages 1-4
  3. Economic and Accounting Rates and Concepts Should Not be Conflated

    1. Front Matter
      Pages 5-5
    2. Elizabeth King
      Pages 7-10
  4. Alternative and Supplementary Approaches to Transfer Pricing

    1. Front Matter
      Pages 50-50
  5. Case Studies

    1. Front Matter
      Pages 65-65
    2. Elizabeth King
      Pages 67-88
    3. Elizabeth King
      Pages 89-100
    4. Elizabeth King
      Pages 101-114
    5. Elizabeth King
      Pages 115-124
    6. Elizabeth King
      Pages 137-144
    7. Elizabeth King
      Pages 145-160
  6. Conclusions

    1. Front Matter
      Pages 181-181
    2. Elizabeth King
      Pages 183-186
  7. Back Matter
    Pages 187-194

About this book

Introduction

Transfer pricing is often identified as the most important tax issue that multinational corporations face. This publication is an extremely useful tool for practitioners and tax directors grappling with complex and contentious transfer pricing issues of various kinds. It contains a series of highly detailed case studies, which draw on the author's two decades as a government economist specializing in transfer pricing and valuation, a transfer pricing economist with Price Waterhouse, and, lastly, an independent consultant. These case studies elucidate the types of intercompany transactions that tax authorities often scrutinize, lay out how one should go about analyzing such transactions under the existing regulatory regime in considerable detail, and illustrate a number of proposed alternative approaches that could substantially reduce compliance costs and the frequency of transfer pricing disputes.

Practitioners and tax directors will find the case studies extremely helpful in formulating defensible transfer pricing policies. The case studies may also be useful in assessing tax exposure attributable to intercompany pricing practices, as required under FASB Interpretation No. 48 (FIN 48). Tax policy analysts will find the evaluation and critique of existing methods and the development of alternative proposals thought-provoking and compelling.

The book is divided into three parts: Part I contains a detailed review and critique of individual transfer pricing methods and the economic premises that underpin them. Part II contains a discussion of proposed alternative transfer pricing methods. Part III contains the aforementioned series of eight case studies, encompassing a broad range of transfer pricing issues. Global trading and certain types of Internet-based businesses, which the current transfer pricing regime does not adequately address, are among the issues covered. Each case study is analyzed under both the existing transfer pricing regime and one or more proposed methods.

Keywords

corporate tax taxation valuation

Authors and affiliations

  • Elizabeth┬áKing
    • 1
  1. 1.Beecher ConsultingBrooklineUSA

Bibliographic information

  • DOI https://doi.org/10.1007/978-0-387-78183-9
  • Copyright Information Springer New York 2009
  • Publisher Name Springer, New York, NY
  • eBook Packages Business and Economics
  • Print ISBN 978-0-387-78182-2
  • Online ISBN 978-0-387-78183-9
  • About this book