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Transfer Pricing

Business Valuation Resources, June 2008, Pages: 88


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Transfer pricing concerns fiscal authorities, as multi-national companies can manipulate transfer prices on services or goods sold to another entity within the corporate family to reduce tax liability. This of course has led to the rise of regulations and oversight, making transfer pricing a serious compliance issue for multi-national companies, and the experts engaged to properly value the true cost of the service or good transferred. Bearing in mind, what works for valuation purposes doesn't necessarily work for transfer pricing purposes; practitioners are advised to be sensitive to the other discipline and gain awareness for when they might be involved in an engagement where transfer pricing is an issue. To help valuation experts further their training in this area, experts Mark Fidelman, Elena Khripounova, John M. Breen, and Perry Urken came together for an information rich, 100-minute teleconference which provided a useful introduction to the transfer pricing world. They detail transfer pricing concepts, the regulatory context, and the most relevant analytical approaches employed for transfer pricing, and lay out areas of potential tension between valuation and transfer pricing. The case studies of familiar valuation scenarios relating to intangibles - but from transfer pricing perspectives - highlight their commonalities and differences.



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