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US Transfer Pricing Topics

Introduction

Transfer Pricing is the legal framework in which the value of goods and services being transacted between related parties is evaluated for tax purposes. The topic is of great importance to companies conducting business in more than one country as tax rates vary considerably and the amount of income attributed to activity in a given country can have significant tax implications.

The subject area is further complicated by the wide range of methodologies used to evaluate related-party transactions in different jurisdictions as well as the diverse array of procedures and reporting requirements regulating the conduct of these transactions. For example, some countries allow values of goods to be set for a class of transactions on an ongoing basis by negotiating an Advance Pricing Agreement with a national tax agency, while others do not offer this option. Similarly, some countries allow a taxpayer to select from among a menu of evaluation methods for pricing related-party transactions, while others adhere to a strict standard as to which standard should be applied in a given case.

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