International Tax

Transfer Pricing: A Case Study (Methods and Documentation) (Portfolio 6912)

  • This Portfolio uses a case study involving a fictional company to provide a practical background on how to prepare a transfer pricing study to meet the regulatory and administrative documentation requirements in the United States and under the OECD Guidelines.

Description

Tax Management Portfolio No. 6912, Transfer Pricing: A Case Study (Methods and Documentation), uses a case study involving a fictional company to provide a practical background on how to prepare a transfer pricing study to meet the regulatory and administrative documentation requirements in the United States and under the OECD Guidelines. The Portfolio uses this fictional example, explanatory text, numerous tables, and sample documents in the Worksheets to take the reader step-by-step through a transfer pricing study. Worksheets also provide an illustrative documentation report, prepared under §6662(e), regarding the intercompany transactions presented in the case study. Similar studies are used by taxpayers to ensure that their transfer prices with related entities will meet the requirements of taxing authorities and fiduciary standards.

This Portfolio may be cited as Levey, Carmichael, Gerdes, and Arthur, 6912 T.M., Transfer Pricing: A Case Study (Methods and Documentation).

 

Table of Contents

I. Introduction
II. Documentation Rules
III. Use of Case Study Format
IV. Functional Analysis
V. Application of Functional Analysis to CPC Organization
VI. Financial Results
VII. Transfer Pricing Methodology
VIII. Comparables Analysis
IX. Summary and Conclusions

Marc-Levey
Marc Levey
Partner
Baker & Mckenzie LLP
Phil Carmichael
Philip Carmichael
Principal Economist
Baker & McKenzie Consulting LLC
gerdes-imke-2015
Imke Gerdes
Partner
Baker&McKenzie
Brian Arthur
Brian Arthur
Associate
Baker & Mckenzie LLP
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