Transfer pricing rules apply to intercompany transactions- transfers of IP rights, issuance of debt and recurring trading operations.
Our publication describes:
o general principles
o transfer pricing methods
o documentation recruitments & transfer pricing studies
These transfer pricing rules are subject to I.R.C Section 482 and relevant Treasury Regulations.
Our write-up also covers regulations that apply one-off exchanges and reorganizations, including capital contributions and distributions subject to Section 367. This part covers outbound transfers of property by U.S. persons to foreign corporations, certain liquidations and inbound exchanges.