Transfer Pricing in the 1990s: Tax and Management Perspectives

Transfer Pricing in the 1990s: Tax and Management Perspectives

Transfer Pricing in the 1990s: Tax and Management Perspectives

Transfer Pricing in the 1990s: Tax and Management Perspectives

Synopsis

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. Tang provides current information on U.S. transfer pricing practices. In addition, the author compares the current practices with those of an earlier study done in 1977. Important issues, including the selection of proper transfer pricing methods and coping with environment variables, are discussed extensively.

Excerpt

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 more than 40 percent of international trade is trade between related entities. More than $360 billion of U.S. foreign trade in 1992 represents intrafirm trade.

In the last fourteen years, I have published two books and many articles on transfer pricing. During the same period, I have also spoken to many corporate executives and government officials on topics related to transfer pricing and intrafirm trade. Many issues in this area remain controversial and unsolved. the focus of debates has shifted, however, from domestic to tax and multinational issues.

I hope to accomplish three objectives with Transfer Pricing in the 1990s: Tax and Management Perspectives. First, I will discuss recent changes in transfer pricing regulations introduced by the U.S. government and its major trading partners. Many of these new regulations may have significant implications to the management of a multinational transfer pricing system. Second, I want to provide readers with current information on U.S. transfer pricing practices. the information was obtained from a survey done in 1990. Another objective is to compare the current practices with those of an earlier study done in 1977 and published in Transfer Pricing Practices in the United States and Japan byPraeger in 1979. Similarities and differences between findings from the two studies will be explained.

Many corporate executives of Fortune 500 companies contributed their time and experience generously to this research. I would like to thank them . . .

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