Accounting for Income Taxes: Uncertain Tax Positions in Transfer Pricing (Portfolio 6910)
At a glance
I. Overview of ASC 740-10 and Its Application to Transfer Pricing
II. Units of Account and Identifying Uncertain Tax Positions Related to Transfer Pricing
III. Recognition of Uncertain Tax Positions Related to Transfer Pricing
IV. Evaluating the Arm's-Length Nature of Intercompany Pricing
V. Measurement Analyses
VI. Disclosures
VII. Stakeholders Who Need to Know About ASC 740-10 and Transfer Pricing
Abstract
The Accounting for Income Taxes: Uncertain Tax Positions in Transfer PricingPortfolio provides guidance on determining the units of account and identifying uncertain tax positions; recognizing uncertain tax positions; and evaluating the arm's-length nature of intercompany pricing. It further explains measurement analyses; disclosures; and the key stakeholders affected by ASC 740-10 in relation to transfer pricing.
The first part of the Portfolio discusses ASC 740-10 and its application to transfer pricing, including a brief overview of the transfer pricing regulatory environment. The authors explain their approach to determining the unit of account for a transfer pricing position, identifying and documenting uncertain tax positions, and applying initial filters.
The Portfolio also covers the recognition of uncertain tax positions and evaluating the arm's-length nature of intercompany pricing, specifically, key considerations when evaluating transfer pricing exposures.