Transfer Pricing For Small And Mid-size Businesses

Learning Objectives

• To identify various types of inter-company transactions that related parties may have (the results may surprise you)
• To identify different methods for pricing sales of goods, royalties, services, and interest
• To identify the documentation requirements for penalty protection
• To recall some of the practical learning tips

Course Description

In taxation and accounting, transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities can adjust intra-group transfer prices that differ from what would have been charged by unrelated enterprises.

More transfer pricing adjustments are at stake in the U.S. tax Court than all other issues combined. Where adopted, transfer pricing rules allow tax authorities to adjust prices for most cross-border intragroup transactions, including transfers of tangible or intangible property, services, and loans. For example, a tax authority may increase a company’s taxable income by reducing the price of goods purchased from an affiliated foreign manufacturer or raising the royalty the company must charge its foreign subsidiaries for rights to use proprietary technology or brand name.

Transfer pricing has become a key area of focus for tax authorities in the United States. Maintaining appropriate documentation of a company’s transfer pricing policies mitigates the risk of a potential tax adjustment during a transfer pricing audit and eliminates the risk of substantial penalties. Taxpayers should proactively develop the support of their intercompany transactions and carefully build a defensible strategy that complies with each country’s requirements. Small and mid-sized businesses count on their CPAs to understand transfer pricing to prevent adjustments and penalties for transactions between related parties. This Online CPE webinar will condense the 150 pages of transfer pricing regulations into a practical guide for CPAs and their clients.

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Overview

• EurCo Forms a Distribution Subsidiary in the U.S.

  2 mins
• Profit Split Methods

  11 mins
• Intangible Property

  18 mins
• CPM - Intangibles

  23 mins
• The transfer Pricing Penalty

  35 mins
• Transfer Pricing Planning to Save Taxes

  46 mins