Welcome to USTransferPricing.com

News and Resources Relating to Transfer Pricing in the United States for International Tax Professionals

International tax professionals surveyed for industry publications usually cite transfer pricing as their number one area of interest. There is a great deal of information available in various periodicals, books, and web sites relating to this important area of tax practice. This site attempts to index and organize some of that information, making it easier for tax professionals — lawyers, accountants, and tax directors — to save time tracking down transfer pricing laws, IRS rulings, court decisions, and news, so that they can spend more time working on the transfer pricing challenges specific to their businesses.

In particular, this site focuses on the transfer pricing environment in the United States, although given the international nature of transfer pricing, some references to other countries are included. We will be adding other country-specific transfer pricing information sites based on the interest of our members.

Please contact us with any comments or suggestions you may have. To submit your input, please email the information to submit@gbisi.com or call us at (617) 795-0519.

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Featured Article

Using Advance Pricing Agreements to Mitigate Transfer Pricing Risk

Advance Pricing Agreements offer companies engaged in related party transactions a useful tool to mitigate transfer pricing risk, as well as some ancillary benefits, but the decision whether to seek an APA should be based on a number of factors. Careful consideration of these factors is necessary to determine whether a given company would be well-advised to seek an APA. Once the decision is made to pursue an APA, there are some additional steps that can be taken to expedite the APA process.

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What's New?

Tax Director's Guide to Transfer Pricing in Asia and Australia Published

With significant recent changes in transfer pricing law and practice in some of Asia's leading economies, GBIS has assembled articles and supplementary materials to provide up-to-date information on the transfer pricing environment there. Coverage includes Australia, China, Hong Kong, India, Japan and Singapore. Available by direct order for just $95 for a limited time. Click here for more information.

Advanced Transfer Pricing Course from the International Management Forum

Improve your transfer pricing expertise! USTransferPricing.com has partered with the International Management Forum to offer our readers the opportunity to particpate in their Advanced Transfer Pricing Course. Learn the latest on Business Restructuring and Valuation, TP Legislation and Guidelines, and other hot topics from highly  acclaimed instructors from Transfer Pricing Associates (TPA), part of the TPA Global Group. Click here for more information.

Join our LinkedIn Group

Connect with other transfer pricing professionals and share information. One recent discussion addressed the timing of the applibility of transfer pricing rules: "Do I have to do an arm's length study in pricing determined before the parties that are involved in that transaction become related parties?" Click here for more information or to join.

Announcing the Tax Director's Guide to International Transfer Pricing: 2010 Edition

The editors of USTransferPricing.com are pleased to announce the newly updated and expanded edition of our bestselling transfer pricing book, the Tax Director's Guide to International Transfer Pricing. The updated articles in this second edition reflect the intense competition for tax dollars among various countries in a time of global recession, during which many tightened their transfer pricing rules and increased enforcement and comes in response to the comments and suggestions of you, our readers. These changes include new rules for Advance Pricing Agreements, intangibles, Cost Sharing Arrangements, reorganizations, and services. The 2010 Edition also includes new Country Overview sections covering Australia, Hong Kong, India, Japan, and Singapore, as well as an entirely updated China section, reflecting the major transfer pricing legislation that recently went into effect. This edition also includes significant revisions to many of our other Country Overviews.

Tax Director's Guide to International Transfer Pricing

[order now] [more information]

More than fifty of the world's leading transfer pricing professionals offer their advice and insights on how to navigate complex issues, including:

• When is an APA Advantageous?
• Understanding the New U.S. Services Regulations
• Transfer Pricing Implications of Reorganizations
• Valuing Intangibles Under Cost Sharing Arrangements
• How to Apply the Best Method Rule

The book also provides a country-by-country review of transfer pricing laws in seventeen major economies, addressing questions such as:

• What transfer pricing methods are accepted?
• Do the local tax authorities favor a given method?
• What dispute resolution mechanisms are available?
• Are APAs allowed and, if so, what are the rules?
• To what extent are international guidelines followed?
• How is the acceptability of comparables determined?
• What are the documentation requirements?
• How are non-compliance penalties calculated?

[Click here for more information]

Try EdgarStat Risk-Free!

By special arrangement with EdgarStat LLC, USTransferPricing.com is now offering our users free no-obligation demo of the EdgarStat Transfer Pricing Valuation Database. EdgarStat makes it easy for a novice user to compile and analyze company financial data for transfer pricing. Behind this simple interface is a wealth of data and functionality. Click here for details or to test drive EdgarStat today!

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