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Transfer Pricing

What is Transfer Pricing?

Transfer pricing refers to the process of establishing prices for cross-border transactions between controlled entities within a multinational corporate group.

Key Considerations:

  • Arm’s length principle requires prices mimic those in comparable uncontrolled transactions.
  • Comparability analysis assesses functions, assets, risks to determine appropriate pricing method from cost-plus to resale price.
  • Contemporary issues involve valuation of intangibles and availability of reliable comparable data.

Example:

During an audit, the IRS challenged royalty fees paid by a U.S. subsidiary to its Irish parent company for brand intangibles, finding the agreed rate non-arm’s length.

Takeaways:

As artificial pricing distorts taxable income across jurisdictions, transfer pricing compliance reduces disputes while preserving group synergies and flexibility. Contemporaneous documentation substantiating arrangements mitigates controversy risks.

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