Category: Accounting

State Transfer Pricing vs. Formulary Approach: Which is Better?

Posted on | by Kelvin

 

Write a paper in the area of Transfer Pricing about State transfer pricing vs the formulary approach – which is better?
The constraints of the paper are as follows:
1. It must relate to Transfer Pricing
2. You provide an Hypothesis statement on what you will prove (I recommend discussing the Hypothesis statement with me.)
3. Describe the transaction being analyzed/discuss or how the hypothesis relates to transfer pricing. That is, what transfer pricing issue are you researching and how it relates to the class.
4. Your paper should include tax/transfer pricing references and tax nomenclature.

 

 

The impact of COVID-19 on a transfer pricing economic analysis.

Posted on | by Kelvin

 

Write a paper in the area of Transfer Pricing about The impact of COVID-19 on a transfer pricing economic analysis.
The constraints of the paper are as follows:
1. It must relate to Transfer Pricing
2. You provide an Hypothesis statement on what you will prove (I recommend discussing the Hypothesis statement with me.)
3. Describe the transaction being analyzed/discuss or how the hypothesis relates to transfer pricing. That is, what transfer pricing issue are you researching and how it relates to the class.
4. Your paper should include tax/transfer pricing references and tax nomenclature.

 

 

Transfer Pricing: A Fair Method for Determining Appropriate Returns?

Posted on | by Kelvin

 

Historically transfer pricing laws are ways a tax authority, like the U.S Internal Revenue Service, can reallocate income, expenses, deduction, et. al., when the tax authority deemed a taxpayer was not charging a ‘fair’ price to the good, service, et. al., produced/performed in its country.
1. Is transfer pricing a ‘fair’ way method for determining the appropriate return to a business activity? What alternative way would you recommend to the tax authority?
2. Compare the alternative method to the current transfer pricing standards.
Can Transfer Pricing be used as a pro-active tool by governments to achieve specific economic results? If so, how could a government enforce a TP regime which is used to achieve an economic result and still be fair to the businesses in the country?

Brazil’s Outgoing Transfer Pricing Law vs. New Law

Posted on | by Kelvin

 

 

Brazil’s transfer pricing standard is based on targeted returns and pricing for business activities. It is in the process of adopting the OECD transfer pricing guidelines.
1. Compare and contrast Brazil’s outgoing transfer pricing law with their new law. In your opinion, which is the best? Make sure in your hypothesis statement to state what parameters you will be using.
2. Are transfer pricing laws, like Brazil’s, more efficient method of pricing from the tax authority’s perspective? … the business’s perspective?

 

OECD BEPS Guidelines vs. U.S. Regulations on Intangible Property Transfer Pricing

Posted on | by Kelvin

The OECD has been debating the most appropriate way to determine the arm’s length price for intangible property. Compare and contrast the OECD BEPS project guidelines for determining the arm’s length price of intangibles with those of the U.S. regulations (§1.482-4 and §1.482-7).
1. Explain the implications of adopting a different standard.
2. How does the OECD guidance on DEMPE to reward intangible property transactions compare to the U.S. IRC section 482 and the corresponding U.S. regulations on the pricing of Intangible property?
3. BEPS 2.0, Pilar 1 Amount B – What are the transfer pricing implications? How would one determine the appropriate return given the diversity of different companies.
4. BEPS 2.0, Pilar 2 – what are the transfer pricing implications?
5. Tax authorities are in the process of adopting BEPS 2.0 Pillar 2. Within Pillar 2.0, a multinational’s earnings will be ‘allocated’ among each country where the company operates.
6. Any other topic which interests you
7. Does Pillar 2 mean the arm’s length standard is dead? …or can the two tax standards co-exist?