Transfer pricing refers to the pricing of goods, services and intellectual property transferred between related entities within a multinational corporation. Companies use transfer pricing to allocate ...

The AICPA provided comments to the IRS on forthcoming proposed regulations that will include the Organisation for Economic Co-operation and Development’s (OECD’s) simplified and streamlined approach ...

Although the regulations offer straightforward grounds for challenging the fanciful transfer pricing method endorsed in Medtronic II, a potential appeal could shed light on broader questions about the ...

The comparable profits method is still often cast as uniquely conceptually flawed among transfer pricing methods and only suitable for use as a last resort, but this characterization often draws ...

This article explores transfer pricing disputes with tax authorities and related disclosures in financial statements. Recent increases in companies’ risk exposure from these controversies have raised ...