US taxman eases transfer pricing rules

by Kevin Reed

More from this author

06 Jan 2009

  • Comments

The US taxman has introduced less 'draconian' transfer pricing rules for multinationals, but has not removed all restrictions, say advisers.

The Internal Revenue Service and US Treasury have eased rules around cost sharing arrangements that provide extra flexibility in transfer pricing schemes, which apply to companies and their foreign partners that share in the cost of developing intanginble property.

The new rules relax how these properties are valued.

'They're not draconian now, but they are still very restrictive,' Ernst & Young director of transfer pricing controversy services David Canale told WebCPA.

'They have a framework called the investor model. They provide more flexibility in how it is implemented versus how they described it in the 2005 regulations, but it's still a fairly restrictive interpretation of how you value this intellectual property. The IRS view is that this establishes an arm's-length price. They provide more guidance outlining methods that they consider provide more of an arm's-length approach.'

Further reading:

Go to WebCPA's story

Visitor comments

blog comments powered by Disqus

Add your comment

We won't publish your address

By submitting a comment you agree to abide by our Terms & Conditions

Your comment will be moderated before publication

  • Send


Financial Planner

The Ministry of Defence Surgeon General’s (SG) Finance Department, Lichfield, Staffordshire, Permanent, Full Time, £ £30,008




Get the latest financial news sent directly to your inbox

  • Best Practice
  • Business
  • Daily Newsletter
  • Essentials


Search for jobs
Click to search our database of all the latest accountancy roles

Create a profile
Click to set up your profile and let the best recruiters find you

Jobs by email
Sign up to receive regular updates with the latest roles suitable for you



Why budgeting fails: One management system is not enough

If budgeting is to have any value at all, it needs a radical overhaul. In today's dynamic marketplace, budgeting can no longer serve as a company's only management system; it must integrate with and support dedicated strategy management systems, process improvement systems, and the like. In this paper, Professor Peter Horvath and Dr Ralf Sauter present what's wrong with the current approach to budgeting and how to fix it.


iXBRL: Taking stock. Looking forward

In this white paper CCH provide checklists to help accountants and finance professionals both in practice and in business examine these issues and make plans. Also includes a case study of a large commercial organisation working through the first year of mandatory iXBRL filing.