Transfer Pricing Methods an Applications Guide - 1Ed - Robert Feinschreiber (John Wiley & Sons)

Sections

Understanding Transfer Pricing
COMPARISON OR DIVISION
Practical Aspects of TransferPricing
RELATIONSHIP OF THE PARTIES
OVERVIEW OF THE TAX CHANGES
APPROACHES TO TRANSFER PRICING
PENALTIES
TRANSFER PRICING STRATEGIES
PARAMETERS TO SUBSTANTIATING TRANSFER PRICING
BASIC DISTINCTIONS
Business Facets of Transfer Pricing
SELECTING A PRICING STRATEGY
DIVISION AND PROFIT CENTER ACCOUNTING
AUTONOMOUS TRANSACTIONS
VERTICAL INTEGRATION AND MANDATED TRANSACTIONS
MANDATED SALES VERSUS AUTONOMOUS SALES
ADMINISTRATIVE ASPECTS OF TRANSFER PRICING
CORPORATE AND DIVISIONAL VANTAGE POINTS
DETERMINING THE NUMBER OF PROFIT CENTERS
BY-PRODUCTS AND JOINT PRODUCTS
COSTING ALTERNATIVES
APPLYING MANDATED FULL-COST TRANSFER PRICING
FULL STANDARD COST TRANSFER PRICES
BEHIND THE STANDARD COST SYSTEM
MANDATED MARKET-BASED TRANSFER PRICING
COST-PLUS MARKUPS
APPLYING THE RESALE METHOD TO INTRACOMPANY TRANSFERS
TRANSFER PRICING IMPLICATIONS FOR AUTONOMOUS BUSINESS UNITS
CONCLUSION
BACKGROUND
OVERVIEW
General Principles and Guidelines
BEST METHOD RULE
COMPARABILITY ANALYSIS
ARM’S-LENGTH RANGE
TRANSFER PRICING AS A DECISION-MAKING PROCESS
TAX AND NONTAX CONSIDERATIONS
Transfer Pricing Basics
ASCERTAINING WHO IS AT RISK
FOREIGN COUNTRY PARTICIPATION IN TRANSFERPRICING
BASICS OF THE TRANSFER PRICING INQUIRY
TRANSFER PRICING REFERENCE MATERIALS
TRANSFER PRICING METHODOLOGIES
TRANSFER PRICING PENALTIES IN THE UNITED STATES
FOREIGN-OWNED BUSINESSES DOING BUSINESS IN THEUNITED STATES
INTRODUCING THE ADVANCE PRICING AGREEMENTPROCESS
Applying Specific Transfer Pricing Techniques
COMPARABLE UNCONTROLLED PRICE METHOD
RESALE PRICE METHOD
COST-PLUS METHOD
NO SAFE HARBOR
Comparable Profits Method
COMPARABLE PROFITS METHOD
COMPARABILITY
CPM EXAMPLES
Comparable Uncontrolled Transaction Method for Intangibles
GENERAL PRINCIPLES AND GUIDELINES
ELIGIBLE METHODS
“INTANGIBLE” AND ITS DEFINITIONS
COMPARABLE UNCONTROLLED TRANSACTION METHOD
COMPARISON OF THE TRANSACTIONS
COMPARABLE INTANGIBLE PROPERTY
COMPARABLE CIRCUMSTANCES
EXAMPLES
APPLYING UNSPECIFIED METHODS FOR INTANGIBLEPROPERTY
COORDINATION BETWEEN TANGIBLE PROPERTY AND INTANGIBLE PROPERTY
SPECIAL RULES FOR TRANSFERS OF INTANGIBLE PROPERTY
FORM OF THE CONSIDERATION
PERIODIC ADJUSTMENTS
EXCEPTIONS TO PERIODIC ADJUSTMENT PROVISIONS
APPLYING THE PERIODIC ADJUSTMENT RULE
OWNERSHIP OF THE INTANGIBLE PROPERTY
INTANGIBLE OWNERSHIP EXAMPLES
LIMITS ON CONSIDERATION
LUMP SUM PAYMENTS
APPLYING THE LUMP SUM PAYMENT RULE
PLANNING OPPORTUNITIES
Transfer Pricing for Services
CHARACTERIZATION CONSIDERATIONS
IMPLEMENTING THE SERVICES—PROPERTY DISTINCTION
ANCILLARY AND SUBSIDIARY SERVICES
COLLATERAL CONCERNS
WHOSE EXPENSE IS IT?
WHEN ARM’S LENGTH CAN EQUAL COST
FAIR MARKET VALUE OF SERVICES
FUTURE DEVELOPMENTS
CONCEPTUAL OVERVIEW
TREASURY’S CONCERNS
Cost Sharing
HISTORICAL PERSPECTIVE
SCOPE, APPLICATION, AND LIMITATIONS OF THE FINALREGULATIONS
QUALIFIED COST-SHARING ARRANGEMENT DEFINED
A qualified cost-sharing arrangement must:
CONTROLLED AND UNCONTROLLED PARTICIPANTS DISTINGUISHED
COSTS
BENEFITS
MEASURING BENEFITS
COMPARING PROJECTED TO ACTUAL BENEFITS
TESTING PROJECTED TO ACTUAL BENEFITS
CONSEQUENCES OF FAILING THE 20 PERCENT TEST
BUY-INS AND BUYOUTS
CHARACTER OF PAYMENTS
CHANGES IN THE REGULATIONS
BASIC PREMISE FOR THE USE OF PROFIT SPLITS
Profit Methods
COMPARABLE PROFIT SPLIT METHOD
RESIDUAL PROFIT METHOD
BEST METHOD ANALYSIS FOR THE PROFIT SPLIT APPROACH
Focus on International Transfer Pricing Issues
Foreign-Owned U.S Corporations Reporting
REGULATIONS
PARTIES AFFECTED
REPORTING CORPORATIONS AND RELATED PARTIES
TAX REPORTING REQUIREMENTS
RECORDS AND COMPUTATIONS
MANDATORY AGENCY AGREEMENTS
SUMMONS PROCEDURE
Organization for Economic Cooperation and Development Guidelines
HISTORY
ACCESS TO THE GUIDELINES
ORGANIZATION OF THE GUIDELINES
DEFINITIONS
ARM’S-LENGTH STANDARD
TRANSFER PRICING METHODS
TRANSFER PRICING ADMINISTRATION
DOCUMENTATION
INTANGIBLE PROPERTY
SERVICES
COST CONTRIBUTION ARRANGEMENT (CCA)
INTRODUCTION TO TRANSACTIONAL NET MARGIN METHOD
Transactional Net Margin Method*
WEAKNESSES AND STRENGTHS OF TNMM
COMPARISON WITH TNMM AND COMPARABLE PROFITSMETHOD
Avoiding Transfer Pricing Penalties
PLANNING
Transfer Pricing Penalties
DETERMINATION OF AN UNDERPAYMENT
TRANSACTIONAL PENALTY
NET ADJUSTMENT PENALTY
SETOFF ALLOCATION RULE
NET ADJUSTMENT PENALTY EXAMPLES
NET SECTION 482 EXCULPATORY PROVISIONS
APPLICATION OF A SPECIFIED SECTION 482 METHOD
SPECIFIED METHOD REQUIREMENT
DOCUMENTATION REQUIREMENTS
Transfer Pricing Penalty Exclusion for Contemporaneous Documentation
GENERAL REQUIREMENTS FOR SPECIFIED SECTION 482 METHODS
PRINCIPAL DOCUMENTS
BACKGROUND DOCUMENTS
TAX RETURN DOCUMENTATION
DOCUMENTING UNSPECIFIED METHODS
Advanced Transfer Pricing Issues
PROPOSALS FOR REVISING THE TRANSFER PRICING AUDIT STRUCTURE
USING DATA SOURCES
Advanced Transfer Pricing
COST ISSUES, EXCESS CAPACITY, AND COST STRUCTURES OVERSEAS
ADVANCE PRICING AGREEMENTS
GRAY MARKET CONSIDERATIONS
CORPORATE GOALS AND STRUCTURE
DETERMINING WHO OWNS THE INTANGIBLES
LIFE-CYCLE BUSINESS ANALYSIS
OVERRELIANCE ON EXTERNAL DATA
DEPENDENCE ON SIC CODE ANALYSIS
SELECTION OF THE BEST TRANSFER PRICING METHOD
“COMPARISON OF FUNCTIONS EMPLOYED” METHODOLOGY
Unfolding Transfer Pricing Issues
USING TOTAL OPERATING EXPENSES
TAX MALPRACTICE ATTORNEY AS YOUR ALLY
TRANSFER PRICING INFORMATION DOCUMENT REQUEST FOR ACQUISITIONS

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Transfer Pricing Methods an Applications Guide - 1Ed - Robert Feinschreiber (John Wiley & Sons) - 2004 [0471573604]

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