TransPrice is a member firm of Quantera Global worldwide

US Transfer Pricing-Statutory Rules/Regulations/Circulas

Relevant Rules, Regulations and Statutory Basis: Transfer pricing regulations are covered by the Treasury Regulations (abbreviated “Treas. Reg.”) § 1.482 (referred to as “The Regulations” or “Section 482”) and Treas. Reg. § 1.6662-6 (“Section 6662”) in the United States (“US”). While the first sentence of Section 482 of the current Internal Revenue Code (“the Code” […]

US Transfer Pricing- How the Arm’s Length Principle Works in Practice

Summary of Article: Detail Article: The most important and enduring feature of the transfer pricing regulations is the notion of the “arm’s length principle,” which is the idea that, for tax purposes, a transfer price is to be determined or evaluated by comparing it to the price that would be paid in an identical (or, […]

US Transfer Pricing Series: Special Areas for Consideration – Intangible Assets

Intangible assets are an increasingly important aspect of modern business, and they present unique challenges for taxation and transfer pricing. Under the Section 482 regulations, intangible assets include a wide range of intellectual property such as patents, designs, copyrights, trademarks, and licenses, as well as contractual rights to use intangibles. Intangible assets must have a […]

Navigating Intra-Group Services in Transfer Pricing: Key Considerations for US Multinationals

Intra-group services refer to the provision of services by one company within a group to another. These services can include a wide range of functions, such as administrative, accounting, legal, and payroll services. Given that intra-group services can be used to shift profits between group companies, tax authorities worldwide are paying increasing attention to the […]

Understanding Cost Sharing Arrangements in US Transfer Pricing

Cost Sharing Arrangements (CSAs) are agreements made between related parties to share costs related to the development of intangibles such as research, development, and intellectual property, excluding technology. The IRS requires a CSA to be a Qualified Cost Sharing Agreement (QCSA) under Section 482 to be able to benefit from domestic rules. The US follows […]

Whatapp Us
Have query? Consult with our experts
Have query? Consult with our experts