Transfer Pricing Methods

Advanced praise for Transfer Pricing Methods
"Feinschreiber and a team of renowned executives have provided the definitive transfer-pricing guide to this challenging area. At a time when many companies are reviewing documents, policies, and procedures, it's wonderful to have a concise, clearly written reference focused on what may be the most critical corporate tax issue."
-Charles R. Goulding, Managing Director, Tax
Cooper Industries, Inc.
"It is refreshing to find a treatise on transfer pricing that combines practical business considerations, economic theory, and a discussion of technical tax rules in a way that is meaningful not only for large corporate enterprises but also small and medium-sized businesses."
-Vikram A. Gosain, JD, CPA, Director of Transfer Pricing
General Electric Capital Corporation
"This well-written book will be useful both to attorneys new to the practice area and to older hands. It includes very helpful discussions on valuation issues that will be particularly useful for in-house counsel and accountants."
-Joseph C. Mandarino, Partner
Troutman Sanders, LLP
"Feinschreiber and his contributors have cogently explained hundreds of useful facets in the transfer pricing field that have taken others volumes to articulate. The busy professional should consider this book in his or her quest for knowledge in the scintillating tax specialty."
-Charles L. Crowley, Partner
ITS/Customs and International Trade Practice, Ernst & Young, LLP
"Transfer Pricing Methods . . . should become a standard tool for every owner-managed and mid-cap multinational."
-Enrique MacGregor, Principal-in-Charge, Transfer Pricing Services
Grant Thornton LLP
"Bob's vast experience in transfer pricing matters has again been captured between the covers of a book. Thank you, Bob, and your contributing colleagues, for producing another valuable helpmate."
-Alan Getz, Vice President and General Manager, Tax
Mitsui & Co., Inc. (U.S.A.)
"Feinschreiber's current publication is a practical handbook that presents transfer pricing tools that can assist tax professionals of mid-sized companies to optimize profits, manage cash flows, and moderate taxes in a defensible manner."
-Per H. Hasenwinkle, National Practice Leader, Transfer Pricing
BDO Seidman, LLP Preface.

PART ONE: UNDERSTANDING TRANSFER PRICING.

Chapter 1. Practical Aspects of Transfer Pricing.

Chapter 2. Business Facets of Transfer Pricing.

Chapter 3. General Principles and Guidelines.

Chapter 4. Transfer Pricing Basics.

PART TWO: APPLYING SPECIFIC TRANSFER TECHNIQUES.

Chapter 5. Comparable Uncontrolled Price Method, Resale Price Method, and Cost-Plus Method.

Chapter 6. Comparable Profits Method.

Chapter 7. Comparable Uncontrolled Transaction Method for Intangibles.

Chapter 8. Transfer Pricing for Services.

Chapter 9. Cost Sharing.

Chapter 10. Profit Methods.

PART THREE: FOCUS ON INTERNATIONAL TRANSFER PRICING ISSUES.

Chapter 11. Foreign-Owned U.S. Corporations Reporting.

Chapter 12. Organization for Economic Cooperation and Development Guidelines.

Chapter 13. Transactional Net Margin Method.

PART FOUR: AVOIDING TRANSFER PRICING PENALTIES.

Chapter 14. Transfer Pricing Penalties.

Chapter 15. Transfer Pricing Penalty Exclusion for Contemporaneous Documentation.

PART FIVE: ADVANCED TRANSFER PRICING ISSUES.

Chapter 16. Advanced Transfer Pricing.

Chapter 17. Unfolding Transfer Pricing Issues.

Index.

ROBERT FEINSCHREIBER is a practicing attorney and counselor, as well as a former CPA. As a partner in the firm of Feinschreiber & Associates, his clients include foreign-owned U.S. businesses, U.S. exporters, and companies facing international tax issues. He has written and edited many books, including the Transfer Pricing Handbook, Third Edition, Export Handbook, and International Mergers and Acquisitions, all published by Wiley.

There has never been an easy-to-use and convenient book that addresses salient and fundamental transfer pricing issues . . . until now. Designed to specifically assist mid-sized businesses facing transfer pricing issues now and in the future, Transfer Pricing Methods is a comprehensive guide that provides in-depth coverage of various transfer pricing methods and applications that are available to today’s mid-sized corporations.

An invaluable reference for all tax managers, CEOs, and CFOs, Transfer Pricing Methods provides a practical focus on the techniques available and their consequences. Featuring contributions from industry experts, complete coverage includes:

• Comparable profits methods
• Cost sharing
• Transactional net-margin method
• Adjustments of interest rates
• Resale price techniques
• Benefiting from the cost-plus method
• Market share
• Organisation for Economic Co-operation and Development guidelines
• Life-cycle analysis
• Use of multiple-year data

Transfer Pricing Methods presents in-depth coverage in five accessible parts:

Understanding the Transfer Pricing Process:
Addresses business issues, general principles, and tax guidelines, with practical transfer pricing advice.

Applying Specific Transfer PricingTechniques:
Examines the specifics of each transfer pricing method.

International Transfer Pricing Issues:
Focuses on international and foreign issues, including the impact of the foreign-owned U.S. corporation provisions that often serve as a backstop to transfer pricing regulations.

Avoiding Transfer Pricing Penalties:
Discusses the penalties for transfer pricing errors or just bad guesswork, examines how to escape these pitfalls, and examines the transfer pricing penalty for contemporaneous documentation infractions.

Advanced Transfer Pricing Issues:
Covers the ownership of intangibles, cost analysis, life cycle issues, and antitrust considerations.

Advanced praise for Transfer Pricing Methods

"Feinschreiber and a team of renowned executives have provided the definitive transfer-pricing guide to this challenging area. At a time when many companies are reviewing documents, policies, and procedures, it’s wonderful to have a concise, clearly written reference focused on what may be the most critical corporate tax issue."
–Charles R. Goulding, Managing Director, Tax
Cooper Industries, Inc.

"It is refreshing to find a treatise on transfer pricing that combines practical business considerations, economic theory, and a discussion of technical tax rules in a way that is meaningful not only for large corporate enterprises but also small and medium-sized businesses."
–Vikram A. Gosain, JD, CPA, Director of Transfer Pricing
General Electric Capital Corporation

"This well-written book will be useful both to attorneys new to the practice area and to older hands. It includes very helpful discussions on valuation issues that will be particularly useful for in-house counsel and accountants."
–Joseph C. Mandarino, Partner
Troutman Sanders, LLP

"Feinschreiber and his contributors have cogently explained hundreds of useful facets in the transfer pricing field that have taken others volumes to articulate. The busy professional should consider this book in his or her quest for knowledge in the scintillating tax specialty."
–Charles L. Crowley, Partner
ITS/Customs and International Trade Practice, Ernst & Young, LLP

"Transfer Pricing Methods . . . should become a standard tool for every owner-managed and mid-cap multinational."
–Enrique MacGregor, Principal-in-Charge, Transfer Pricing Services
Grant Thornton LLP

"Bob’s vast experience in transfer pricing matters has again been captured between the covers of a book. Thank you, Bob, and your contributing colleagues, for producing another valuable helpmate."
–Alan Getz, Vice President and General Manager, Tax
Mitsui & Co., Inc. (U.S.A.)

"Feinschreiber’s current publication is a practical handbook that presents transfer pricing tools that can assist tax professionals of mid-sized companies to optimize profits, manage cash flows, and moderate taxes in a defensible manner."
–Per H. Hasenwinkle, National Practice Leader, Transfer Pricing
BDO Seidman, LLP