Transfer Pricing Rules and Compliance Handbook

Topics and Contents

1 Introduction
2 General Principles of Code Sec. 482
3 Methods for Transfers of Tangible Property
4 Methods for Transfers of Intangible Property
5 Intercompany Services
6 The Comparable Profits Method
7 Intercompany Leases, Loans and Advances
8 Encouraging Compliance: Penalties
9 Preparing Transfer Pricing Documentation
10 Overall Strategy for Compliance and Controversy
11 Advance Pricing Agreements
12 Impact of Transfer Pricing on Other Tax Issues
13 Impact of Transfer Pricing on Non-Tax Regulatory Issues
 
APPENDICES
 
Appendix 1 Glossary of Transfer Pricing Terms
Appendix 2 Comparison of Transfer Pricing Methods
Appendix 3 Transfer Pricing Documentation Example
Appendix 4 Transfer Pricing Dispute Procedural Flowchart
Appendix 5 Global Rules, Regulations and Guidelines
Appendix 6 Global Penalties on Transfer Pricing Assessments
Appendix 7 Global Documentation Requirements
Appendix 8 APA Program in Other Countries
Appendix 9 Other Transfer Pricing Publications