A Practical Process and Approach to Implementing the New Transfer Pricing Service Regulations Issued by the IRS.
The new transfer pricing services regulations recently issued by the IRS pose significant challenges for many companies with international operations. This report walks the reader through the necessary steps to determine which provisions of the regulations are applicable to a given transaction and how to achieve compliance.
The practical review and implementation process described by the authors offers guidance on key issues, including how to identify fully-loaded cost pools for each cost services center, how to conduct a functional analysis, and how to determine the arm's length charge.
The report also examines the transfer pricing methods allowed for services transactions, including the new Services Cost Method, and offers guidance regarding which method is appropriate to a given transaction. Also included is a checklist of necessary implementation actions.
*Please note that this article is too short to contain a table of contents*
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