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Transfer Pricing In The 1990s Book

Transfer Pricing In The 1990s
Transfer Pricing In The 1990s, Transfer pricing is a dynamic and multidimensional topic that has captured the attention of academicians, corporate executives, and tax authorities for many decades. The issues of transfer pricing are very complex and the stakes are extremely high because, Transfer Pricing In The 1990s has a rating of 2.5 stars
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Transfer Pricing In The 1990s, Transfer pricing is a dynamic and multidimensional topic that has captured the attention of academicians, corporate executives, and tax authorities for many decades. The issues of transfer pricing are very complex and the stakes are extremely high because, Transfer Pricing In The 1990s
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  • Transfer Pricing In The 1990s
  • Written by author Roger Y. W. Tang
  • Published by Greenwood Publishing Group, Incorporated, January 1993
  • Transfer pricing is a dynamic and multidimensional topic that has captured the attention of academicians, corporate executives, and tax authorities for many decades. The issues of transfer pricing are very complex and the stakes are extremely high because
  • This volume examines major tax and management issues related to transfer pricing in the 1990s. Recent changes in transfer pricing regulations introduced by the U.S. government and its major trading partners are explained.
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Tables and Figures
Preface
IIntroduction1
Intrafirm Transactions in a Corporate Environment3
Megatrends and the Significance of Intrafirm Transactions in International Trade5
The Need for a Multidisciplinary Approach11
Overview of the Book11
2The New Tax Environment of Transfer Pricing - A U.S. Perspective17
Major Legislation and Regulations in the United States17
Surveillance and Investigation of Transfer Pricing Practices19
Recent Changes in Transfer Pricing Regulations21
Some Audit Techniques Used by IRS Examiners28
3New Transfer Pricing Regulations in Canada, Japan, South Korea, and the European Community33
The Importance of Transfer Pricing to Canada33
Transfer Pricing Regulations in Canada37
New Regulations in Japan39
Rules and Regulations in South Korea41
New Tax Directives and Conventions in the EC42
4Research Methodology and Profile of Respondent Firms49
Current Literature on Transfer Pricing49
Evaluation of Current Literature59
Content of the Questionnaire60
The Survey and Profile of the Respondent Firms60
5Transfer Pricing Methods67
The Magnitude of Intracompany Transfers68
The Extent of Usage of Transfer Prices68
Pricing Methods for Intracompany Transactions69
Company Size and the Orientation of Transfer Prices72
Some Guidelines for Selecting Transfer Pricing Methods74
6Environmental Variables of International Transfer Pricing81
The Stakeholders in International Transfer Pricing and Their Conflicting Interests81
Prior Research on Environmental Variables83
Responses by Multinational Firms - An Overview85
Responses to the 1990 and 1977 Studies - A Comparison87
Results from a Factor Analysis90
7Other Issues and Conclusions99
Systems' Objectives and Policy Authority99
How Policy Disagreements Were Resolved101
Policies on Outside Purchases of Intermediate Goods103
Implications from the Research104
App. A: Survey Questionnaire109
App. B: Section 482 of the Internal Revenue Code Allocation of Income and Deductions Among Taxpayers113
App. C: Sections 69(1), 69(2), and 69(3) of the Canadian Income Tax Act of 1972114
App. D: Information Circular 87-2 of Revenue Canada, February 27, 1987, International Transfer Pricing and Other International Transactions116
App. E: Sections 770 to 773 of the U.K. Income and Corporation Taxes Act of 1988131
Index139


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