U.S. Specific Tax Rules
U.S. transfer pricing rules are lengthy. They incorporate all of the principles above, using CPM (see below) instead of TNMM. U.S. rules specifically provide that a taxpayer's intent to avoid or evade tax is not a prerequisite to adjustment by the Internal Revenue Service, nor are nonrecognition provisions. The U.S. rules give no priority to any particular method of testing prices, requiring instead explicit analysis to determine the best method. U.S. comparability standards limit use of adjustments for business strategies in testing prices to clearly defined market share strategies, but permit limited consideration of location savings.
Read more about this topic: Transfer Pricing
Famous quotes containing the words specific, tax and/or rules:
“No more distressing moment can ever face a British government than that which requires it to come to a hard, fast and specific decision.”
—Barbara Tuchman (1912–1989)
“In 1845 he built himself a small framed house on the shores of Walden Pond, and lived there two years alone, a life of labor and study. This action was quite native and fit for him. No one who knew him would tax him with affectation. He was more unlike his neighbors in his thought than in his action. As soon as he had exhausted himself that advantages of his solitude, he abandoned it.”
—Ralph Waldo Emerson (1803–1882)
“The early Christian rules of life were not made to last, because the early Christians did not believe that the world itself was going to last.”
—George Bernard Shaw (1856–1950)