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Section 482 does not priorities the specific methods. That is, a taxpayer may pick the best method based on the taxpayer’s analysis. Should the U.S. abandon the best method analysis principle and codify the order of which methods should be used?
Comparability analysis – to implement the arm’s length standard, one must look at similar transactions. To determine if a transaction is similar the concept of Comparability Analysis has been developed by tax authorities. Potential papers on comparability analysis...
Would a country safe harbor price be better for a company than the arm’s length method?
Compare the United Nations Transfer Pricing Manual and OECD Transfer Pricing guidelines? What are the major differences?
Arm’s Length Standard – does it fit in the new global tax environment?
Arm’s Length, Fair Market Value, Market Price and Fair Price: 1) which standard provides the best measure for intercompany pricing and why is it better than the arm’s length method. 2) What are the pros and cons of each method?
