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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. This book examines many important tax and management issues related to transfer pricing. These issues include new transfer pricing regulations and their implications, the selection of proper transfer pricing methods, major environmental variables, and issues concerning the administration of a transfer pricing system. The author also presents many interesting findings from a recent study on U.S. transfer pricing practices.
The author begins by describing the nature of intrafirm transactions in a corporate environment and the significance of intrafirm transactions in international trade. Recent changes and major transfer pricing legislation and regulations in the United States are explained. New transfer pricing regulations in Canada, Japan, South Korea, and the European Community and their implications are also discussed. These are followed by a presentation on research methodology and profile of 143 respondent firms. The author then explains the findings on transfer pricing methods and environmental variables of international transfer pricing. Current transfer pricing practices are compared with those of an earlier study done in 1977. Other issues such as system objectives, resolution of policy conflicts, and policies on outside purchases are covered by this monograph. General conclusions from this research and suggestions for further research are also provided.
List of contents
Preface
Introduction
The New Tax Environment of Transfer Pricing--A U.S. Perspective
New Transfer Pricing Regulations in Canada, Japan, South Korea, and the European Community
Research Methodology and Profile of Respondent Firms
Transfer Pricing Methods
Environmental Variables of International Transfer Pricing
Other Issues and Conclusions
Appendixes
Index
About the author
ROGER Y. W. TANG is Professor of Accountancy at the Haworth College of Business Administration, Western Michigan University, where he also holds the Upjohn Chair of Business Administration. He has taught at the University of Nebraska, McGill University, and the University of Calgary, and is a member of the American Accounting Association, the Academy of International Business, the Institute of Management Accountants, and the Institute of Certified Internal Auditors. Dr. Tang has published widely in the important journals serving his field and is the author of three earlier books, including Transfer Pricing in the 1990s: Tax and Management Perspectives (Quorum, 1993) and Transfer Pricing Practices in the United States and Japan (Praeger, 1979).
