Treatment of Intercompany Transfer Pricing for Tax Purposes: A Survey of Legislative and Administrative Issues

September 1, 1992

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Yuichi Ikeda. Treatment of Intercompany Transfer Pricing for Tax Purposes: A Survey of Legislative and Administrative Issues, (USA: International Monetary Fund, 1992) accessed September 20, 2024

Disclaimer: This Working Paper should not be reported as representing the views of the IMF.The views expressed in this Working Paper are those of the author(s) and do not necessarily represent those of the IMF or IMF policy. Working Papers describe research in progress by the author(s) and are published to elicit comments and to further debate

Summary

Tax authorities in several countries have intensified their surveillance of intercompany transfer pricing in recent years. This paper examines the legislative and administrative issues related to the treatment of intercompany transfer pricing for tax purposes. It reviews the existing international guidelines and national rules on methods for determining appropriate transfer prices, as well as the issues related to tax administration practices for the implementation of those rules. Various systems, proposed or introduced to improve the predictability of taxation, are also examined. This paper further reviews the recent discussions on the “commensurate-with-income” standard and the pricing methodologies proposed thereunder. It finally reviews some alternative approaches to international income allocation which are proposed or adopted in lieu of the transfer pricing approach.

Subject: Double taxation, National accounts, Personal income, Revenue administration, Tax avoidance, Taxes, Transfer pricing, Transfer pricing rules

Keywords: Adjustment practice, Arm's length, Arm's length price principle, Assist state authorities, Customs duty, Double taxation, Global, Income tax, Multinational enterprise, Partner country, Personal income, Personnel assist state authorities, Rate of return, Tax authorities, Tax authority, Tax avoidance, Tax liability, Transfer pricing, Transfer pricing issue, Transfer pricing method, Transfer pricing rules, Withholding tax, WP

Publication Details

Pages:

60
Volume:

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DOI:

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Issue:

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Series:

Working Paper No. 1992/077
Stock No:

WPIEA0771992
ISBN:

9781451849929
ISSN:

1018-5941

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