The Resource An examination of the new U.S. transfer pricing proposals

An examination of the new U.S. transfer pricing proposals

Label
An examination of the new U.S. transfer pricing proposals
Title
An examination of the new U.S. transfer pricing proposals
Subject
Summary
This article provides an analysis of the proposed transfer pricing regulations by the IRS and the Treasury including periodic adjustments and joint ownership of intangibles.The author criticizes the profit methods and the great burden they impose on data gathering and evaluation, especially as regards unrelated parties. Particular attention is paid to the following: commensurate-with-income standard, periodic adjustments, safe harbours, exact and inexact comparables, priority of methods and cost sharing agreements
Citation source
In: Tax notes international. - Arlington. - Vol. 4 (1992),
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • cost sharing arrangement
  • profit split method
  • intangibles
Label
An examination of the new U.S. transfer pricing proposals
Instantiates
Publication
Abbreviated title
TaxNint
Label
An examination of the new U.S. transfer pricing proposals
Publication
Abbreviated title
TaxNint

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