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International Transfer Pricing

Published on Nov 18, 2015

A brief discussion of international transfer pricing methods used for cross border sales of tangible property between related parties

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PRESENTATION OUTLINE

1.

International Transfer Pricing

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2.

Transfer Pricing Methods

Sales of Tangible Assets
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3.

Subject to IRS Scrutiny

  • They can audit pricing
  • They can adjust pricing
  • They can assess penalties
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4.

Acceptable Pricing Methods

  • IRS Wants Best Method
  • That Means Arms Length
5.

1 - Comparable Uncontrolled Price Method

This is the preferred method
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Example

  • Sale to unrelated party
  • Similar to the related buyer
  • Similar economic environment
  • Adjust as necessary
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7.

2 - Resale Price Method

Sales Price Minus Reasonable Gross Profit
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Appropriate For Sales To Distributors

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3 - Cost Plus Method

COGS Plus Reasonable Gross Profit
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10.

Appropriate For Sales To Manufacturers

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Transfer Pricing Methods

  • Comparable Uncontolled Price
  • Resale Price
  • Cost Plus
  • There Are Others....
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Chris Farrell, CPA
Chris@Goldcocpa.Com
@GoldsteinandCo

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